Minnesota DWI Lawyer Blogs on Minnesota DWI: This Week's Featured Minnesota Case

The Minnesota DWI Case of the Week is State v. Beall, _ N.W.2d. _ (Minn.App. 8/23/09). Beall is a pretrial appeal by the State where it challenged the District Court's ruling that the stop of the defendant's vehicle for an inoperable center brake light did not constitute a reasonable articulable suspicion of a violation of the law.

The defendant argued at the suppression hearing that the stop of his vehicle was not valid because his vehicle was equipped with two working stop lights as required by Minn. Stat. § 169.57, subd. 1(a)(2006). The District Court agreed with the defendant concluding that, "because Beall's vehicle had two working brake lights as required by Minn. Stat. § 169.57, subd. 1 (a), the inoperable third brake light did not give [the officer] a reasonable articulable basis to stop the vehicle". Id. at _.

On Appeal the Appellate Court observed, "Generally, if an officer observes a violation of a traffic law, no matter insignificant the traffic law, that observation forms the requisite particularized and objective basis for conducting a traffic stop". Id. The Court of Appeals then noted, "While we agree with the district court that such a vehicle would not be operated in violation of Minn. Stat. § 169.57, subd. 1(a), the district court failed to consider that Minn. Stat. § 169.57, subd. 3(a) requires that '[w]hen a vehicle is equipped with stop lamps or signal lamps, such lamps shall at all times be maintained in good working condition. Minn. Stat. § 169.47, subd. 1 (2006), provides, in relevant part, that '[i]t is unlawful ... for any person to ... fail to perform any act required under this chapter.' A vehicle with an inoperable center brake light is operated unlawfully in violation of Minn. Stat. § 169.57, subd. 3(a). Observation of such a violation gives rise to objective, reasonable, articulable suspicion justify a traffic stop. " Id. (Emphasis the court's).

The Minnesota Court of Appeals rejected, "...as without merit Beall's assertion that 'such lamps' as used in section 169.57, subd. 3(a), refers only to two statutorily required lamps: the provision unambiguously applies to all lamps with which a vehicle is equipped. And, the provision in Minn. Stat. § 169.57, subd. 4, prohibiting certain alterations and installations to federally required center brake lights, 'if the alteration or installation alters or obscures any portion of the lamp or affects the intensity of light emitted,' demonstrates that the legislature is aware of the importance of operable, unaltered center brake lights." The Court of Appeals then held that the district court erred by holding that the stop was not justified.

Moral of the Story: When it comes to brake lights, if you got them, you better flaunt them!


F.T. Sessoms, Minnesota DWI Attorney