West v. State
2016 Del. LEXIS 386
| Del. | 2016Background
- At ~2:00 a.m. Officer Gaul followed Tracey West for 3–4 miles after observing her vehicle drift back and forth within its lane and once strike the shoulder; as West merged onto a ramp to Route 1 she nearly hit a concrete island and made a sharp corrective swerve.
- Officer Gaul activated lights and stopped West; upon contact he detected a strong odor of alcohol, observed signs of impairment, arrested her for DUI, and the improper-lane-change charge was later dismissed.
- West moved to suppress post-stop evidence, arguing the stop lacked reasonable suspicion under the Fourth Amendment; the Court of Common Pleas denied suppression (invoking the community-caretaker doctrine), and a jury convicted her of DUI.
- The Superior Court affirmed, citing both the community-caretaker doctrine and, alternatively, that West’s erratic driving supplied reasonable, articulable suspicion of DUI. West appealed to the Delaware Supreme Court.
- The Delaware Supreme Court affirmed the Superior Court but rested its decision on the alternative ground: viewing the totality of circumstances objectively (including patrol-car video), the drifting plus the near-collision and sharp swerve gave rise to reasonable suspicion to stop and investigate for DUI.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of the stop under the Fourth Amendment (reasonable suspicion of DUI) | West: Officer lacked reasonable and articulable suspicion to stop her for DUI; stop therefore unconstitutional and evidence should be suppressed. | State: Erratic driving (weaving within lane for miles + near collision and sharp swerve) objectively supported reasonable suspicion to stop and investigate for DUI. | Held: Affirmed — objective facts (weaving then nearly hitting concrete island and sharp corrective swerve) provided reasonable suspicion for an investigatory stop for DUI. |
| Applicability of the community-caretaker doctrine to justify the stop | West: Community-caretaker exception did not apply to justify a seizure of a moving vehicle to investigate DUI. | State: Trial court and Superior Court relied on community-caretaker rationale to justify the stop as a welfare check. | Held: Court did not decide the doctrine’s application; affirmed on the alternative ground of reasonable suspicion and deemed resolving the doctrine unnecessary. |
| Scope and timing of DUI investigation (pre- vs post-stop indicators) | West: Any odor/signs of intoxication arose only after the stop, so pre-stop facts did not justify a DUI-focused stop; at most a lane-violation stop would allow only lane-related inquiries. | State: The pre-stop driving pattern objectively suggested impairment and justified a stop to inquire about fitness to drive. | Held: Court treated objective pre-stop facts as sufficient for a DUI investigatory stop; concurrence would have rested on a reasonable mistaken belief in a lane violation instead. |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes that brief investigative stops are permissible on reasonable, articulable suspicion)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (objective-reasonableness governs traffic-stop analysis regardless of officer’s subjective motives)
- Navarette v. California, 134 S. Ct. 1683 (U.S. 2014) (totality-of-circumstances/common-sense approach to reasonable suspicion in traffic-stop context)
- Heien v. North Carolina, 135 S. Ct. 530 (U.S. 2014) (Fourth Amendment tolerates reasonable mistakes of fact or law by officers)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (appellate review of reasonable-suspicion/probable-cause questions is de novo with factual findings given due weight)
- Jones v. State, 745 A.2d 856 (Del. 1999) (Delaware standard: reasonable suspicion evaluated objectively through eyes of reasonable, trained officer)
- Bloomingdale v. State, 842 A.2d 1221 (Del. 2004) (officer may develop DUI suspicion after a stop for moving violations; scope of stop must be tied to its purpose)
- Lopez-Vazquez v. State, 956 A.2d 1280 (Del. 2008) (recognizing deference to officer training/experience when evaluating reasonable suspicion)