State v. Stevens, 1612000849

On Dec. 1, 2016, Corporal Donaldson (K-9 handler) observed Dennis L. Stevens make a turn without signaling and initiated a traffic stop.
Donaldson asked for license, registration, and insurance; Stevens searched his car but could not produce documents, then started his vehicle and fled.
Officers pursued; Stevens committed additional traffic infractions, stopped suddenly, collided with Donaldson’s patrol vehicle, reversed into it twice, exited and ran on foot.
Officer Angelo tackled Stevens; the K-9 “Ripper” engaged and injured both Angelo and Stevens during the capture.
Stevens was charged with multiple offenses including resisting arrest, improper turn, driving while suspended, failure to have registration/insurance, reckless endangering, and assault.
Stevens moved to suppress all evidence, arguing the initial stop was illegal/pretextual; State argued the stop was supported by a traffic violation and officer motive is irrelevant under controlling law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of traffic stop	Stevens: stop was illegal for lack of reasonable suspicion and was pretextual	State: Donaldson observed a turn without signal — a traffic violation providing probable cause	Stop was valid; observing a failure to signal supported probable cause to initiate stop
Relevance of officer's subjective motive	Stevens: Heath requires inquiry into officer intent when pretext is alleged	State: Whren forecloses subjective-motive inquiry; motive irrelevant to Fourth Amendment reasonableness	Court follows Whren and Delaware precedent — subjective intent is irrelevant to stop’s constitutionality
Suppression of evidence derived from the stop	Stevens: fruits of an unlawful stop must be suppressed	State: because stop was lawful, evidence is admissible	Motion to suppress denied; evidence not excluded
Procedural defect in motion (page limit)	Stevens filed over-length motion	State: procedural rule violation noted but merits review favored	Court deemed defect de minimis and considered the motion on the merits

Whren v. United States, 517 U.S. 806 (1996) (officer's subjective motivations do not affect Fourth Amendment analysis of traffic stops)
Turner v. State, 25 A.3d 774 (Del. 2011) (recognizes officer discretion in traffic stops and declines to rely on subjective motives)
Traylor v. State, 458 A.2d 1170 (Del. 1983) (Delaware law allows officer discretion to arrest for motor vehicle violations)
Pierson v. State, 338 A.2d 571 (Del. 1975) (probable cause assessed from the four corners of the affidavit)
Di's Inc. v. McKinney, 673 A.2d 1199 (Del. 1996) (court preference to decide motions on merits)
State v. Heath, 929 A.2d 390 (Del. Super. Ct.) (case advocating motive inquiry; not followed by this court)