Most DUI arrests in Pennsylvania arise out of traffic stops. Law enforcement agents can only stop and question motorists for certain reasons, however, and if they surpass the scope of their authority, the stop may be illegal, and any evidence obtained during the stop may arguably be inadmissible. Recently, a Pennsylvania court assessed the reasonableness of a stop that led to a DUI arrest in a case in which it ultimately denied the defendant’s motion to suppress. If you are charged with a DUI offense, you should meet a Pennsylvania DUI defense attorney as soon as possible.
It is reported that a police officer noticed the defendant operating a pickup truck without an inspection sticker. The officer approached the vehicle in the defendant’s driveway, inquiring about the inspection sticker. The defendant admitted that the vehicle was not registered, his license was suspended, and he had no insurance. The officer asked for paperwork, and when checking the VIN, he detected alcohol on the defendant’s breath, leading to field sobriety tests, the defendant’s arrest, and a blood test indicating a blood alcohol content of 0.169.
It is alleged that the defendant was charged with a DUI offense. Prior to trial, he filed a motion to suppress the evidence obtained during his discussion with the officer, arguing that the officer opened the driver’s side door without permission. The trial court denied the defendant’s motion. He was convicted, after which he appealed.
Grounds for Suppressing Evidence in DUI Cases
On appeal, the court upheld the trial court’s ruling. In the first issue, the defendant argued that Trooper Bivens had unlawfully prolonged the traffic stop, invoking the Supreme Court’s decision in Rodriguez v. United States, which held that the authority to detain an individual for a traffic stop terminates when the “mission” of the stop ends unless there is additional reasonable suspicion or probable cause to extend the stop.
The specific focus of the defendant’s argument was on the actions of the officer who conducted the traffic stop. The defendant claimed that the officer exceeded the scope of the stop by opening the driver’s side door, which he believed was a pretext to check the accuracy of VIN that had already been recorded. The defendant argued that the officer could have simply issued citations for various violations, such as not having a valid inspection, registration, and driving under suspension, without the need to open the car door.
The court, however, found that the defendant’s argument was misplaced. The court clarified that Rodriguez primarily addresses the reasonableness of a seizure and does not directly address the authority to conduct a search. Therefore, the claim that the officer unlawfully extended the stop by opening the car door without consent was not directly related to the duration of the stop, as defined by Rodriguez.
The court also highlighted that the officer did not observe any signs of intoxication during the stop, which could have justified an extended detention to investigate a DUI. The decision to open the car door led to the discovery of potential discrepancies in the VIN, which required further analysis related to the search aspect of the case.
Ultimately, the court concluded that the officer was authorized to confirm the accuracy of the VIN, as this action was consistent with the ongoing mission of the traffic stop. The records check had not provided any information about the vehicle, and the trooper’s actions were deemed reasonable in the circumstances.
Notably, the court’s decision did not address whether the search itself was constitutionally authorized but focused on the lawfulness of the stop’s duration, emphasizing that the appellant’s argument had little relevance to the search’s authorization.
Meet with an Experienced Pennsylvania DUI Defense Attorney
If you are charged with a DUI crime, it is in your best interest to meet with an attorney to discuss your rights. Attorney Zachary B. Cooper is an experienced Pennsylvania DUI defense attorney who is adept at helping people obtain favorable outcomes in DUI matters, and if you hire him, he will work tirelessly on your behalf. You can contact Mr. Cooper through the online form or at (215) 542-0800 to arrange a free and confidential meeting.