945 F. Supp. 2d 665
E.D. Va.2013Background
- Officer Purdy observed Williams weaving and touching the right fog line on Route 36 during a nighttime patrol near Fort Lee.
- The initial observation showed Williams drive on top of the right fog line for a few feet but not across it, prompting closer attention.
- Video later showed Williams repeatedly weaving and touching fog/center lines as he traveled in and out of his lane.
- Officer Purdy believed Williams could be intoxicated and decided to stop for failing to maintain a single lane and for possible DUI, based on experience with similar cases.
- The stop occurred after Williams’ vehicle weaved back and forth with multiple touches of the fog line, under no adverse weather conditions.
- Defendant was charged with conspiracy to steal government property, theft of government property, illegal provision of alcohol to a minor, possession of marijuana, and failure to maintain lane; the suppression motion challenged the stop as unsupported by reasonable suspicion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was reasonable suspicion to stop for failure to maintain a single lane of travel | Williams | Williams | Yes; the officer had reasonable suspicion |
| Whether there was reasonable suspicion to stop for driving while intoxicated | Williams | Williams | Yes; officer had reasonable suspicion |
Key Cases Cited
- United States v. Branch, 538 F.3d 328 (4th Cir. 2008) (reasonable suspicion must be evaluated by totality of circumstances with officer experience considered)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality of the circumstances standard; inferences reasonable under training and experience)
- United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion may justify stop based on predictive inferences)
- Whren v. United States, 517 U.S. 806 (1996) (probable cause not required for brief investigatory detention in traffic stops; reasonableness varies by circumstance)
- United States v. Mubdi, 691 F.3d 334 (4th Cir. 2012) (reasonable mistake of fact in traffic stop does not require suppression when belief is reasonable)