178 F. Supp. 3d 1250
S.D. Ala.2016Background
- On Dec. 15, 2015, Garcia (driver) and Bustamante (passenger) were stopped on I-10 by Lt. Cayton after an alleged lane change without signaling; a subsequent vehicle search uncovered suspected narcotics.
- Defendants moved to suppress, arguing the traffic stop was illegal, detention was unlawfully extended, arrests lacked probable cause, and the search lacked warrant/consent; an evidentiary hearing was scheduled for factual disputes.
- The dispositive legal question addressed was whether Alabama law requires a signal whenever a driver changes lanes, even if the lane change can be made safely without signaling.
- Defendants contended Section 32-5A-133(a) only requires a signal when the movement cannot be made with reasonable safety (relying on a Georgia decision, Bowers).
- The government and the Court concluded the statute plainly contains two independent requirements: (1) the movement must be safe, and (2) the driver must give an appropriate signal — i.e., signaling is always required when moving right or left upon a roadway.
- The Court held that failing to signal a lane change violated Alabama law and therefore Lt. Cayton did not act under a mistake of law that would defeat probable cause for the stop; remaining challenges require an evidentiary hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of initial traffic stop | Stop lawful only if officer had probable cause for a traffic violation | Garcia: Ala. Code §32-5A-133(a) does not require a signal if movement can be made with reasonable safety | Court: Statute requires a signal for every turn or move right/left; failure to signal supports probable cause for stop |
| Whether officer made a mistake of law | Officer's belief lawful if based on correct statutory reading | Defendants: Officer made an impermissible mistake of law because signaling not always required | Court: Officer did not err; statute clearly mandates signal regardless of safety of movement |
| Statute vagueness re: what constitutes an "appropriate signal" | Defendants: statute vague about required signal for lane changes | Govt: no allegation Garcia signaled at all; failure to signal is unambiguous violation | Court: Even assuming some vagueness, Garcia gave no signal; violation plain and supports stop |
| Need for evidentiary hearing on further suppression issues | N/A (government) | Defendants: factual disputes about detention, probable cause, consent, purse search | Court: Factual issues remain; evidentiary hearing set to resolve them |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (pretextual traffic stops are evaluated under objective probable-cause standard)
- United States v. Chanthasouxat, 342 F.3d 1271 (11th Cir. 2003) (mistake of fact can supply reasonable suspicion/probable cause; mistake of law cannot)
- Bowers v. State, 473 S.E.2d 201 (Ga. App. 1996) (construed Georgia statute to require signal only if movement would affect other traffic)
- Swann v. City of Huntsville, 455 So.2d 944 (Ala. Crim. App. 1984) (noting Alabama rules of the road derived from Uniform Vehicle Code)
- City of Prichard v. Baizer, 95 So.3d 1 (Ala. 2012) (statutory construction requires giving effect to legislative intent)
- Brown v. Endo Pharmaceuticals, Inc., 38 F. Supp. 3d 1312 (S.D. Ala. 2014) (recognizing Alabama law prohibits changing lanes without signaling)
- Hudson v. Hall, 231 F.3d 1289 (11th Cir. 2000) (cited regarding Georgia case treatment)