Mike Brotherton pled guilty to a first offense of driving under the influence (DUI) and received a suspended sentence of eleven months and twenty-nine days, with ten days to be served on weekends. He reserved a certified question regarding the legality of the traffic stop that led to his arrest. The Tennessee Court of Criminal Appeals found that the trooper, Michael Sullivan, lacked reasonable suspicion to initiate the stop, thus dismissing the charge.
During the motion to suppress hearing, Trooper Sullivan testified that he observed Brotherton's vehicle with a "busted" taillight at approximately 12:20 AM while patrolling State Route 219. Although he noted that Brotherton was weaving within his lane, he did not observe any lane violations. Sullivan stopped Brotherton based on the broken taillight, despite it being operational, and detected a strong odor of alcohol. He found an open twelve-pack of beer in Brotherton's vehicle, who admitted to consuming five or six beers.
Sullivan acknowledged that he initially believed there was a violation but did not closely inspect the taillight. He stated that he often allowed vehicles with violations to continue for several miles before stopping them, indicating that the broken taillight was primarily a safety concern for himself due to the lack of other traffic. The court ultimately reversed the Circuit Court's judgment and dismissed the DUI charge based on the insufficiency of grounds for the stop.
The trooper testified that the taillight in question was not in 'good condition' as per the statute's interpretation. He defined a 'glaring' light as one brighter than usual and concluded that 'good condition' is determined by common sense rather than a legal definition. The trooper indicated that the only proper repair method was to replace the broken lens, despite having seen various taillights fixed with red tape. He acknowledged that many vehicles he did not stop also had taillights in poor condition. The trial court upheld the validity of the stop, agreeing that the taillight was indeed not in good condition, providing the trooper with sufficient reason for the stop.
The defendant raised two issues for appellate review: 1) the constitutionality of Tennessee Code Annotated section 55-9-402 due to vagueness, and 2) whether the trooper had reasonable suspicion to conduct the traffic stop. The court referenced the case State v. Preston, which outlines the requirements for a certified question of law to be considered on appeal, emphasizing that the question must be clearly defined and the trial judge must agree on its significance. Additionally, it noted that the failure to reserve a certified question properly could lead to dismissal of the appeal. The defendant's vagueness claim was dismissed for lack of proper reservation, and the court stated it lacked jurisdiction over that issue. The legality of the trooper's stop was examined under Tennessee Code Annotated section 55-9-402, which mandates that all motor vehicles must have operational tail lamps in good condition.
The central issue is whether the defendant's taillight was 'in good condition and operational' as required by Tennessee Code Annotated section 55-9-402(c). The trial court upheld the traffic stop based on its finding that the taillight was not in 'good condition,' despite the defendant's use of repair tape on the damaged cover. The defendant argues that his taillight met the legal standard, asserting that the trooper lacked reasonable suspicion for the stop.
Legal precedent establishes that a traffic stop is valid if an officer has probable cause to believe a traffic violation occurred, regardless of the officer's motivations (Whren v. United States). The court must evaluate the totality of the circumstances to assess reasonable suspicion (State v. Binette). At a suppression hearing, the trial court's factual findings are presumed correct unless proven otherwise (State v. Daniel), with the burden on the defendant to show that evidence contradicts the trial court’s conclusions (Braziel v. State).
During the hearing, the trooper testified he observed the defendant's broken taillight while on patrol at 12:20 a.m. He noted that the taillight emitted light when brakes were applied and followed the defendant for approximately two and three-quarter miles without observing any other traffic violations. The trial court ultimately found the taillight was significantly covered with red repair tape, indicating it was not in 'good condition.' The statute does not define what constitutes 'good condition' for a taillight.
The defendant cites a Sixth Circuit ruling stating that a broken taillight with a hole and missing piece violates Tennessee Code Annotated section 55-9-402 (c) and establishes probable cause for a traffic stop (United States v. Johnson, 242 F.3d 707, 710 (6th Cir. 2001)). However, the term 'good condition' is not defined in this context, nor is it clarified whether repairs would restore a taillight to 'good condition.' Previous cases have affirmed that vehicles without working taillights or with non-working brake lights justify traffic stops due to reasonable suspicion (State v. Aaron Leon Burnette, Jr., No. W2006-02092-CCA-R3-CD, 2007; State v. Calvin T. Barham, No. W2002-00246-CCA-R3-CD, 2002). Like Johnson, these cases do not specify the definition of 'good condition.' The Sixth Circuit emphasized that the legality of a traffic stop hinges on whether officers had probable cause to suspect a violation, rather than whether a court would convict for the infraction.
In this case, while the defendant's taillight was broken, there was evidence of an attempted repair, and the trooper testified that the taillight was operational and posed no safety risk at the time of the stop. The court concluded that the taillight was in working condition, not perfect, nor in pristine condition, and that legislative intent does not require vehicles to be in factory condition. The court noted that the defendant's repair efforts demonstrated an attempt to maintain vehicle safety. Ultimately, the trooper's observation of the operational brake light, which initially attracted his attention, indicated that the stop lacked reasonable suspicion. The trial court's judgment was reversed, and the indictment was dismissed.
