State v. Lynch
961 N.E.2d 534
Ind. Ct. App.2012Background
- Officer Kivett observed Lynch driving east on Washington Street at about 1:00 a.m. and noted a center turn-only lane; the lane is marked 'turn-only' with arrows.
- Lynch allegedly turned left onto Arsenal Street from a lane to the right of the designated turn-only lane, not from the turn-only lane itself.
- Kivett stopped Lynch for an improper left turn from a lane clearly designated for turning and then observed signs of intoxication.
- Lynch moved to suppress all evidence from the stop, arguing there was no reasonable suspicion to initiate the stop.
- The trial court granted Lynch’s suppression motion, and the State appealed arguing the stop was supported by reasonable suspicion.
- The issue centers on whether Lynch violated local and state left-turn requirements and what constitutes the center line for a five-lane roadway.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion to stop? | Lynch contends there was no traffic infraction and no reasonable suspicion. | State argues Lynch violated left-turn rules, justifying the stop. | Yes; reasonable suspicion existed to stop Lynch. |
| How must 'center line' be interpreted on a five-lane, turn-only roadway? | Center line could be the middle lane as a whole. | Center line is the outer boundary of the turn-only lane for the driver's direction. | Center line is the outer edge of the turn-only lane for the relevant travel direction. |
| Do the applicable statutes require a particular left-turn methodology to establish a violation? | Lynch argues no violation under the cited statutes; the stop rests on a mistaken belief of law. | State maintains Lynch violated IC 9-21-8-21 and related ordinance provisions. | Yes; the left-turn from the designated lane was required, supporting the stop. |
Key Cases Cited
- Goens v. State, 943 N.E.2d 829 (Ind. Ct. App. 2011) (police may detain for infractions when supported by reasonable suspicion)
- Gunn v. State, 956 N.E.2d 136 (Ind. Ct. App. 2011) (reasonable suspicion review is de novo on appeal)
- State v. Renzulli, 958 N.E.2d 1143 (Ind. 2011) (standard for reviewing suppression rulings)