State v. Vinson
400 S.C. 347
| S.C. Ct. App. | 2012Background
- Trooper Horne observed Vinson drift across the double yellow lines in a no-passing zone on SC Highway 215 at ~3:00 a.m.
- Based on experience, statistics, lack of other traffic, time, and location, trooper suspected Vinson was intoxicated and stopped him to avoid field sobriety tests on slopes.
- Upon contact, Vinson’s eyes were bloodshot and an odor of alcohol was detected; Vinson admitted drinking four or five beers in the hour before arrest.
- Vinson performed two field sobriety tests, failed, re-tested unsuccessfully, and was arrested for driving under the influence; breath test at the station yielded 0.14 BAC.
- Vinson moved to suppress the stop; circuit court denied, relying on 56-5-1900 to justify the stop; Vinson was tried and convicted November 10, 2009.
- On appeal, the court reviews Fourth Amendment legality under the totality of circumstances and affirms the circuit court’s ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was justified by reasonable suspicion under 56-5-1900 | Vinson | Vinson contends no violation; stop invalid absent lane violation | Yes; reasonable suspicion supported by literal lane violation and totality of circumstances |
| Whether Vinson’s lane crossing violated 56-5-1900(a) and justified the stop | Vinson | Vinson argues no practicable violation under statute | Yes; crossing the no-passing zone violated the statute and supported the stop |
| Whether the stop was unconstitutional under the Fourth Amendment as applied to this traffic stop | Vinson | Stop permissible with probable cause or reasonable suspicion | Affirmed; stop deemed reasonable under totality of circumstances |
Key Cases Cited
- State v. Burgess, 394 S.C. 407, 714 S.E.2d 917 (Ct.App.2011) (stop permissible with reasonable suspicion for traffic violation)
- State v. Pichardo, 367 S.C. 84, 623 S.E.2d 840 (Ct.App.2005) (totality of circumstances governs Fourth Amendment analysis)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (stop valid if reasonable under totality of circumstances)
- State v. Corley, 383 S.C. 232, 679 S.E.2d 187 (Ct.App.2009) (subjective intent irrelevant in probable-cause analysis)
- Banda v. State, 371 S.C. 245, 639 S.E.2d 36 (Ct.App.2006) (review standard for Fourth Amendment issues in criminal cases)
- Rogers v. State, 368 S.C. 529, 629 S.E.2d 679 (Ct.App.2006) (appellate review limited to evidence supporting circuit court findings)