State v. Rhodes, 950 N.E.2d 1261

Rhodes accompanied a friend to retrieve a vehicle that had been towed; a towing employee reported Rhodes appeared belligerent and possibly drunk.
Officer Giordano, off-duty near Last Chance Wreckers, followed Rhodes after the towing employee’s report.
Rhodes left the towing lot, Giordano stopped him for a traffic violation and possible intoxication.
Rhodes argued the stop was unlawful and that the officer lacked reasonable suspicion.
The trial court granted Rhodes’s motion to suppress; the State appeals the suppression ruling.
The appellate court affirms, holding the State failed to prove a valid traffic violation or reasonable suspicion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a traffic violation justification existed	Rhodes lacked a signaling violation under law	State contends Rhodes violated signaling statute and could be stopped	No valid traffic violation established; stop invalid
Whether the stop was supported by reasonable suspicion	St. John’s tip alone could indicate intoxication	Tip plus corroboration could create reasonable suspicion	No reasonable suspicion; stop unsupported

State v. Washington, 898 N.E.2d 1200 (Ind. 2008) (standards for reviewing suppression orders and necessity of probative evidence)
State v. Lucas, 859 N.E.2d 1244 (Ind. Ct. App. 2007) (reversal only when record lacks conflict and supports opposite view of trial court)
Finger v. State, 799 N.E.2d 528 (Ind. 2003) (reasonable suspicion requires totality of circumstances)
Moultry v. State, 808 N.E.2d 168 (Ind. Ct. App. 2004) (totality-of-circumstances test for reasonable suspicion)
Ransom v. State, 741 N.E.2d 419 (Ind. Ct. App. 2000) (officer’s mistaken belief about violation not protected by good faith)
State v. Quirk, 842 N.E.2d 334 (Ind. 2006) (traffic stop based on even minor violations gives probable cause)