State v. Loyd, 326 S.W.3d 908

Loyd was convicted by a jury of driving while intoxicated (DWI) and driving while revoked, with sentences suspended and probation lasting two years.
The stop leading to arrest occurred after Loyd left a casino parking lot in Kansas City, Missouri, around 2:00 a.m. on August 25, 2008.
Loyd challenged the stop by moving to suppress evidence on the basis that the officer lacked reasonable suspicion or probable cause.
The trial court never formally ruled on the motion to suppress at trial, but a suppression hearing occurred the morning of trial.
On appeal, Loyd contends the stop was unlawful because police lacked probable cause to believe a traffic violation occurred.
The Western District granted Loyd’s point, holding the stop was not supported by probable cause and reversing and remanding the conviction and sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the stop have probable cause?	Loyd argues no probable cause to stop him.	State contends several possible traffic violations gave probable cause.	Stop lacking probable cause; reversal and remand.

State v. Pike, 162 S.W.3d 464 (Mo. b anc 2005) (burden on State to prove suppression legality)
State v. Granado, 148 S.W.3d 309 (Mo. banc 2004) (routine traffic stop constitutional if lawful)
State v. Johnson, 148 S.W.3d 338 (Mo. App. W.D. 2004) (probable cause and traffic stop analysis)
State v. Sund, 215 S.W.3d 719 (Mo. banc 2007) (review of suppression rulings based on evidence)
State v. Abeln, 136 S.W.3d 803 (Mo. App. W.D. 2004) (slight center-line crossing not enough for stop)
State v. Whalen, 49 S.W.3d 181 (Mo. banc 2001) (cannot supply missing evidence or rely on speculation)