An intoxicated driver, Mike Brotherton, was stopped by Trooper Michael Sullivan in Carroll County after the officer perceived a broken taillight on Brotherton's vehicle. After the trial court denied Brotherton's motion to dismiss based on lack of reasonable suspicion for the stop, he pleaded guilty to driving under the influence but reserved the legality of the stop for appeal. The Court of Criminal Appeals reversed the conviction, ruling that the officer lacked reasonable suspicion. The Supreme Court of Tennessee granted the State's application to appeal, focusing on the reasonable suspicion standard regarding broken taillights. The Supreme Court concluded that the trial court's determination of reasonable suspicion was correct, reversing the Court of Criminal Appeals' judgment. The facts indicated that the officer observed a bright light from the vehicle's taillight and noted the vehicle weaving within its lane before initiating the stop. Upon approaching, the officer detected signs of intoxication, including the smell of alcohol and the presence of beer in the vehicle. Brotherton was arrested for DUI and other offenses, but charges unrelated to the DUI were later dismissed at a preliminary hearing.
The broken taillight charge against Mr. Brotherton was dismissed after he repaired the taillight following his February 4 arrest. However, he was indicted by the Carroll County grand jury on May 7, 2007, for driving under the influence (second offense) and violating the implied consent law. On May 29, 2007, Mr. Brotherton filed a motion to suppress evidence obtained from the February 4 traffic stop. During the hearing, Trooper Sullivan testified that the taillight was broken and covered with red repair tape, which had a hole allowing light to shine through, thereby violating Tennessee law regarding motor vehicle lights. The trial court, after reviewing photographs and the trooper's testimony, found that the stop was justified based on specific and articulable facts, denying Mr. Brotherton's motion to dismiss.
Facing strong evidence against him, Mr. Brotherton entered a plea agreement to plead guilty to driving under the influence (first offense) while reserving a certified question regarding the validity of the stop. The Court of Criminal Appeals later reversed the trial court's decision, determining that Trooper Sullivan lacked reasonable suspicion to stop Mr. Brotherton, as the taillight was operational and had been repaired. The State's application for permission to appeal was granted to address the legality of the traffic stop. The review of the trial court's suppression decision will defer to its factual findings unless the evidence suggests otherwise, while legal conclusions will be reviewed de novo.
The Fourth Amendment of the U.S. Constitution and Article I, Section 7 of the Tennessee Constitution protect against unreasonable searches and seizures, asserting that traffic stops are considered seizures that grant full constitutional protections. Authorities must have probable cause or a reasonable suspicion of a traffic violation to initiate a stop, as established in cases such as Whren v. United States and Delaware v. Prouse. Reasonable suspicion requires specific, articulable facts that warrant the intrusion, and cannot be based on vague hunches. Tennessee courts have emphasized a particularized basis for suspicion and the totality of circumstances in assessing reasonable suspicion. The law permits traffic stops for equipment violations, as seen in State v. England, which affirmed that a violation of specific equipment requirements can create reasonable suspicion. The statute in question mandates that vehicles have two red tail lamps and two stoplights, that the stoplight not project glaring light, and that all lamps be in good condition. The Court of Criminal Appeals focused on the "good condition" requirement, concluding that Mr. Brotherton's repaired taillight met this standard, despite the lack of a statutory definition for "good condition."
The Court of Criminal Appeals concluded that Mr. Brotherton's taillight was in working condition, differentiating it from a previous case where a broken taillight justified a vehicle stop. The court noted Mr. Brotherton's efforts to repair his taillight but ultimately found it not in perfect condition. It ruled that Trooper Sullivan lacked reasonable suspicion of a traffic violation. However, reasonable suspicion does not require a confirmed violation; it only necessitates a belief that a violation might have occurred. The proper analysis should focus on whether Trooper Sullivan had an articulable suspicion that Mr. Brotherton's taillight was in violation of the law. The court ultimately agreed that Trooper Sullivan did have reasonable suspicion based on the condition of the taillight, which had a hole in the repair tape allowing bright white light to shine through, similar to the prior case's facts. This condition potentially violated Tenn. Code Ann. 55-9-402(b), which mandates two red taillights, and also violated the prohibition against glaring lights as defined by the statute. Thus, the observations made by Trooper Sullivan were sufficient to justify the stop.
Trooper Sullivan identified a bright white light emitted from a taillight on Mr. Brotherton's vehicle, which he deemed to be a "glaring light," exceeding the normal brightness expected from a vehicle's taillight. This observation provided reasonable suspicion for initiating a traffic stop. The court clarified that while Tenn. Code Ann. 55-9-402 does not require taillights to be maintained in showroom condition, the presence of a taillight that is both broken and inadequately repaired with taillight repair tape can constitute reasonable suspicion for an investigatory stop. The court reversed the Court of Criminal Appeals’ judgment, affirmed the trial court's conviction, and remanded the case for further proceedings, with costs taxed to Mike Brotherton.
