693 F. App'x 835
11th Cir.2017Background
- Phillip Scott was stopped after an officer observed Scott signal while changing lanes but not give 100 feet of notice before the lane change.
- Scott was thereafter charged with possession with intent to distribute 50 grams or more of methamphetamine; he moved to suppress evidence obtained after the traffic stop.
- The district court denied the motion to suppress; Scott appealed, arguing the stop lacked probable cause because Ala. Code § 32-5A-133 does not require a 100-foot signal before a lane change.
- The Eleventh Circuit reviewed factual findings for clear error and legal conclusions de novo, and considered whether the officer’s interpretation of the Alabama statute was an objectively reasonable mistake of law under the Fourth Amendment.
- The court found the statutory text ambiguous about whether the 100-foot signal requirement applies to lane changes as well as turns.
- Because the officer’s belief that the statute required a 100-foot signal for a lane change was objectively reasonable, the stop was valid and the denial of suppression was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was supported by probable cause/reasonable suspicion under Ala. Code § 32-5A-133 because Scott did not signal 100 feet before changing lanes | Scott: § 32-5A-133 does not require a 100-foot signal for lane changes, so no traffic violation occurred and the stop lacked probable cause | Government: The statute is ambiguous and an officer reasonably could believe the 100-foot requirement applies to lane changes; any mistake of law was objectively reasonable | The court held the statute is ambiguous and the officer’s mistaken belief was objectively reasonable, so the stop was valid and suppression denial affirmed |
Key Cases Cited
- United States v. Ramirez-Chilel, 289 F.3d 744 (11th Cir. 2002) (standard of review for suppression rulings)
- Delaware v. Prouse, 440 U.S. 648 (1979) (traffic stops are seizures under the Fourth Amendment)
- United States v. Strickland, 902 F.2d 937 (11th Cir. 1990) (probable cause exists where officer observes a traffic infraction)
- United States v. Harris, 526 F.3d 1334 (11th Cir. 2008) (traffic-stop probable cause and reasonable-suspicion principles)
- Heien v. North Carolina, 135 S. Ct. 530 (2014) (an objectively reasonable mistake of law can justify a stop)
- United States v. McCullough, 851 F.3d 1194 (11th Cir.) (officer’s objectively reasonable misreading of Alabama license-plate statute upheld stop)
- United States v. Carabello, 595 F.3d 1214 (11th Cir. 2010) (court may affirm suppression denial on any ground supported by the record)
- United States v. Alvarado-Zarza, 782 F.3d 246 (5th Cir. 2015) (distinguished — interpreted different Texas statute regarding 100-foot signaling requirement)