State v. Huffman
185 Wash. App. 98
| Wash. Ct. App. | 2014Background
- Trooper observed Huffman weaving and crossing the center line on SR 9, culminating in a full center-line crossing by one tire width; he stopped Huffman and arrested her for DUI.
- Huffman moved to suppress all post-stop evidence; the district court granted suppression, finding no lawful basis for the stop.
- RALJ appeal led to a reversal by the superior court, which held the stop valid as Huffman violated RCW 46.61.100 (center-line crossing).
- The State sought discretionary review to determine whether RCW 46.61.140’s ‘as nearly as practicable’ language applies to RCW 46.61.100 and harmonizes the statutes.
- The court held that the ‘as nearly as practicable’ qualifier does not apply to RCW 46.61.100, affirming the stop as lawful and reinstating charges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does crossing the center line violate RCW 46.61.100? | Huffman argues center-line crossing is not a traffic infraction under 46.61.100. | State contends the crossing is a violation of 46.61.100 and justifies the stop. | Yes; crossing the center line constitutes a 46.61.100 infraction. |
| Should 46.61.140’s ‘as nearly as practicable’ apply to 46.61.100? | Huffman urges harmonization by importing 140’s standard into 100. | State argues the two statutes are distinct and 140 does not apply to 100. | No; the qualifier does not apply to 46.61.100. |
| Is Prado controlling in this context? | Huffman relies on Prado to limit 140’s reach and argue no stop under 100. | State contends Prado is limited to 140 and does not govern 100. | Prado is limited to 140; it does not control 46.61.100 analysis. |
Key Cases Cited
- State v. Prado, 145 Wn. App. 646 (Wash. Ct. App. 2008) (brief lane incursions analyzed under 46.61.140)
- State v. Nichols, 161 Wn.2d 1 (Wash. Sup. Ct. 2007) (lane-line violations under 46.61.140)
- Swinomish Indian Tribal Cmty. v. Dep’t of Ecology, 178 Wn.2d 571 (Wash. Sup. Ct. 2013) (statutory interpretation framework; plain meaning governs)
- In re Pers. Restraint of Skylstad, 160 Wn.2d 944 (Wash. S. Ct. 2007) (statutory interpretation and harmony of language)
- Lake v. Woodcreek Homeowners Ass’n, 169 Wn.2d 516 (Wash. S. Ct. 2010) (plain meaning rule; end-point of ambiguity inquiry)