State of Minnesota v. Vernon Lee Williams. MN traffic stop, brake light
On April 23, 2013, a Minneapolis police officer noticed a car turning one direction after signalling a turn in the other direction. The officer believed that the driver might be trying to avoid him, and decided to investigate. He briefly lost sight of the car, but then caught up. He noticed the center brake light was illuminated, but only at one third of its capacity. He pulled the car over, and then determined that the driver, Vernon Lee Williams, had a driver's license that had been cancelled as inimical to public safety. He arrested Williams, who was charged with driving after cancellation.
Williams moved to suppress the evidence from the stop, and argued that the officer had no reason to pull him over. The State argued that the stop was justified because Minnesota Statute 169.57, which requires brake lights to be "maintained in good working condition." The Hennepin County District Court agreed with Williams and suppressed the evidence, since the brake light was operational, although dimmer than normal. The state brought a pretrial appeal to the Minnesota Court of Appeals.
The Court of Appeals agreed with the prosecution. It held that plain meaning of "good working condition did not include a brake light functioning at one-third of its capacity. Even though this might be adequate or sufficient, the statute requires more. Since the brake light was not in good working condition, the officer was justified in making the stop. Therefore, the Court of Appeals reversed and remanded the case.
No. A13-1787 (Minn. Ct. App. Mar. 24, 2014).
Please see the original opinion for the court's exact language.
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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