West v. Delaware

Tracey West was pulled over by police officer Thomas Gaul when her car was drifting back and forth in the lane. The officer saw the car swerve sharply to avoid hitting a concrete island. When he approached the car, Gaul smelled alcohol. West "staggered out of the car" and failed field sobriety tests. She was charged with an illegal lane change and driving under the influence. Before trial, West moved to suppress the evidence that she was intoxicated. She claimed that Officer Gaul lacked the reasonable suspicion required by the Fourth Amendment to make an investigative stop of her car. Thus, any evidence of her intoxication gathered after the stop should have been suppressed. After hearing testimony from the officer and reviewing the video from the police car camera, the trial judge dismissed the lane change charge, but denied the motion to suppress. The State then introduced at trial the evidence of her intoxicated state, and a jury convicted West of drunk driving. West appealed her conviction to the Superior Court, which affirmed the trial court’s ruling on the community caretaker doctrine, and also found that Officer Gaul had reasonable suspicion to stop West for driving while intoxicated. West then appealed to the Delaware Supreme Court, arguing the community caretaker doctrine did not apply, and Officer Gaul lacked reasonable suspicion as required by the Fourth Amendment for an investigatory stop of her car. Finding no reversible error, the Supreme Court affirmed. View "West v. Delaware" on Justia Law