State v. Sanchez, 33 Neb. Ct. App. 495

Tina M. Sanchez was a passenger in a pickup truck stopped by police after the vehicle exited a gas station parking lot onto a public road without signaling.
Officers had prior knowledge of the vehicle's and occupants' connections to drug offenses and used a drug detection dog during the stop.
A search revealed methamphetamine, a scale with residue, open alcohol, and drug paraphernalia in Sanchez’s possession.
Sanchez was charged and convicted of possession of a controlled substance with intent to distribute, failure to affix a drug tax stamp, drug paraphernalia possession, and possession of an open alcoholic container.
Sanchez moved to suppress all evidence from the stop, arguing the stop was unlawful because signaling is not required when exiting a private lot onto a roadway.
The district court denied her motion to suppress, interpreting Nebraska law to require a signal when turning onto a public road from a private lot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop lawful under Neb. Rev. Stat. § 60-6,161?	Signaling not required turning from private lot; no violation	Signaling required when turning onto roadway from anywhere	Stop lawful—statute requires signal when entering roadway
Was the traffic stop pretextual and thus invalid?	Officer’s motive was really to search for drugs	Officer’s motive irrelevant if objective violation occurred	Officer’s motive irrelevant; violation justified the stop

State v. Jasa, 297 Neb. 822 (traffic violation provides probable cause for stop)
State v. Shiffermiller, 302 Neb. 245 (standard of review for motions to suppress)
State v. Thalken, 299 Neb. 857 (officer’s subjective motive not relevant to validity of stop)
State v. Nolan, 283 Neb. 50 (ulterior motive is irrelevant if valid traffic violation established)
State v. Seckinger, 301 Neb. 963 (probable cause based on totality of circumstances)