State v. Schroeder, 2011 Mo. LEXIS 3

On October 13, 2006, Schroeder was stopped in Franklin County after his bright headlights were on as Trooper Keathley passed him.
Schroeder, who had no license, admitted drinking six beers and failed a preliminary breath test.
Schroeder performed field sobriety tests, failing the one-leg stand and displaying horizontal gaze nystagmus and balance issues.
Schroeder was arrested for DWI, advised of Miranda rights, and refused to provide a breath sample.
The trial court convicted Schroeder of DWI, DWR, and failure to dim headlights; he was sentenced accordingly.
Schroeder appealed, challenging the headlight ruling, suppression ruling, and vagueness of the DWI statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for failing to dim headlights	Schroeder argues no evidence showed 300-foot glare to another vehicle.	State contends evidence shows headlights glared when within 300 feet.	Evidence sufficient to support verdict.
Lawfulness of roadside encounter and traffic-stop justification	Keathley lacked observed traffic violation before stopping.	Encounter justified to check for assistance and for enforcement of headlight statute.	Encounter lawful; stop supported by safety/assistance rationale.
Miranda warnings during roadside questioning	Miranda warnings required before any custodial questioning.	Questions were during a routine stop to confirm suspicions; no Miranda breach.	No Miranda violation; questioning within permissible stop.
Vagueness of Missouri DWI statutes (577.010/577.001) as applied	Statutes vague, fail to define 'intoxicated condition' with adequate notice.	Missouri precedent defines 'intoxicated condition'; statute not void for vagueness as applied.	Statutes not unconstitutionally vague as applied to Schroeder.
Sufficiency of evidence supporting DWI conviction under statute	Arguments centered only on headlights; no impairment evidence tied to operation.	Trial evidence (slurred speech, balance issues, breath test, field sobriety results) supports impairment.	Conviction affirmed on DWI statute.

Berkemer v. McCarty, 468 U.S. 420 (1984) (roadside questioning during traffic stops not required to warn; Terry framework)
State v. Pike, 162 S.W.3d 464 (Mo. banc 2005) (reasonable suspicion for traffic stops)
State v. Keeth, 203 S.W.3d 718 (Mo. App. 2006) (limited questioning in patrol car confirms suspicions; no Miranda needed)
State v. Johnson, 55 S.W.2d 967 (Mo. 1932) (ordinary understanding of 'intoxicated condition')
State v. Raines, 62 S.W.2d 727 (Mo. 1933) ('intoxicated condition' means impairment of driving ability)
State v. Cox, 478 S.W.2d 339 (Mo. 1972) (drunk driving standard linked to impairment)
State v. Self, 155 S.W.3d 756 (Mo. banc 2005) (vagueness challenge limited to applied context)