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State of Minnesota v. Darryl Dewayne Gibson, Jr. MN traffic stop
The defendant in this Minnesota case was driving on Interstate 90 and took the Highway 59 exit in Worthington. At the end of the exit ramp was a stop sign and a stop line painted on the roadway. The defendant stopped, but only after his vehicle had completely crossed the line. A Worthington police officer made a traffic stop for a violation of Minn. Stat. 169.30(b), which requires a driver to stop "at a stop sign or at a clearly marked stop line before entering the intersection". The violation was apparently captured on video.
During the traffic stop, the officerk noticed items in the car that were consistent with forgery. The defendant was arrested and moved to suppress the evidence.
The district court granted the motion, holding that the traffic stop was unlawful. The district court concluded that the stop must be at the intersection, and not necessarily at the stop sign or stop line. The state appealed to the Court of Appeals, which reversed, holding that the statute required the driver to "stop at, near, or in proximity to the stop sign and stop line."
The defendant asked the Minnesota Supreme Court to hear the case, which it agreed to do. The high court affirmed the Court of Appeals, reversing the lower court's decision.
The court's decision focused on the meaning of the words "stop at." "Stop" was easy, since the court defined this as a "complete cessation from movement." Since there had been a complete stop, the court zeroed in on the meaning of the word "at." It noted that it had to focus on the plain meaning, which might be dependent upon context.
The Court turned to the Oxford English Dictionary, which stresses that "at" means a particular place or position. Thus, the court noted that the statute is not merely a suggestion, but a "mandatory requirement for traffic control and safety."
The defendant found a dictionary which defined "at" as "in or near the position of." He thus argued that since he stopped near the sign, this was all that was required. But the court rejected this definition, saying that it "transforms a precise stopping location into a nebulous stopping area."
The defendant also pointed to some statutes stressing the need to stop before entering a highway, which he had done. But the court pointed out that while these statutes might require a driver to stop a second or even third time, this did not remove the requirement to stop at the line.
In this case, the entire car was past the line when the driver stopped. The court seemingly left open the question of whether there would be a different result if part of the car were behind the line. The court noted that it was unnecessary to discuss "various hypotheticals regarding the spatial relationship of the stopped vehicle to the stop sign or stop line."
For these reasons, the Supreme Court affirmed the Court of Appeals and sent the case back to the District Court.
No. A19-0675 (Minn. July 8, 2020).
Please see the original opinion for the court's exact language.
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Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia , 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).
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