Staten v. State
946 N.E.2d 80
| Ind. Ct. App. | 2011Background
- Staten was stopped after Indiana State Trooper Greer observed him disobey a three-way stop sign on an access road to Boonville Junior High School.
- Greer smelled alcohol and administered field sobriety tests; Staten failed and consented to a chemical test.
- The Chandler Police Department administered a blood test showing BAC of 0.15%.
- Staten was charged with Class A OWI endangering a person, Class A OWI with BAC ≥0.15, Class C OWI, Class C failing to obey a stop sign, and Class C driving on the wrong side of the road.
- A bench trial resulted in convictions for the OWI and stop-sign infraction, with a later corrective judgment vacating the BAC-based OWI and the stop-sign conviction.
- The trial court later remained with the OWI endangering conviction and the $5 Class C fine; Staten appeals the convictions and the corrected judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of the traffic stop to admit BAC evidence | Staten: stop was illegal; misapprehension of violation invalidates stop | Staten: stop based on a mistaken violation invalidates evidence | Traffic stop upheld; BAC evidence admissible |
| Sufficiency of evidence for endangering a person | Staten argues no actual endangerment proven | Staten: intoxication plus minor infraction insufficient to prove endangerment | Sufficient evidence to prove endangerment beyond reasonable doubt |
| Constitutional basis for stop and legal elements of stop-sign infraction | State argues through intersection designation; through-highway elements met | State failed to prove through-highway or proper designation; stop invalid | Stop valid under theory of minor traffic violation; through-highway elements not established; Class C stop-sign infraction vacated |
Key Cases Cited
- Datzek v. State, 838 N.E.2d 1149 (Ind.Ct.App. 2005) (admission of evidence and abuse of discretion standard)
- Quirk, 842 N.E.2d 334 (Ind.2006) (police may stop for minor traffic violations; probable cause not required for stop)
- Jackson v. State, 785 N.E.2d 615 (Ind. Ct. App. 2003) (validity of traffic stop when objective justification exists)
- Smith v. State, 754 N.E.2d 502 (Ind.2001) (abuse of discretion standard for evidentiary ruling)
- Outlaw v. State, 918 N.E.2d 379 (Ind.Ct.App. 2009) (endangerment element requires more than intoxication)
- Krohn, 521 N.E.2d 374 (Ind.Ct.App. 1988) (endangerment not purely hypothetical; substance of danger matters)
- Staley v. State, 895 N.E.2d 1245 (Ind.Ct.App. 2008) (endangerment requires actual risk considerations beyond mere intoxication)
- Vanderlinden v. State, 918 N.E.2d 642 (Ind.Ct.App. 2009) (context for endangerment analysis in OWI cases)
- Cash v. State, 593 N.E.2d 1267 (Ind.Ct.App. 1992) (illegality of stop based on mistaken belief of violation; exclusion of evidence)