Minnesota DWI Attorney F. T. Sessoms Blogs on Minnesota DWI: This Week's Featured Minnesota DWI Case

The Minnesota DWI Case Of The Week is State v. Nolden (Decided January 31, 2022, Minnesota Court of Appeals, Unpublished), which stands for the proposition that you are still "equipped" even if your bulbs are gone.

In Nolden, the defendant's jeep liberty was stopped by a Beltrami County Sheriff's deputy because the center brake light on the jeep did not illuminate when the vehicle's brakes were activated. When the deputy approached the Defendant's vehicle, he noticed that there wasn't a brake light cover over the center light cavity and he could see the wiring inside the cavity which appeared to have previously housed the brake light.

The Defendant was subsequently arrested for a DWI and he filed a motion to suppress all of the evidence arguing that the initial stop was illegal. 

Minnesota law requires that “[w]hen a vehicle is equipped with stop lamps or signal lamps, the lamps must at all times be maintained in good working condition.” Minn. Stat. § 169.57, subd. 3(a) (2020). The Defendant's argument was that his vehicle was not “equipped” with a center brake light pursuant to the “plain reading” of Minn. Stat. § 169.57, subd. 3(a) “because the entire [brake light] fixture was absent from the vehicle at the time in question.” In short, defendant argues, his “vehicle did not have a faulty or malfunctioning third brake light” because “it simply had no light at all.”

The district court denied the motion to suppress and on appeal, the Minnesota Court of Appeals upheld the district court, stating:

"Although “equipped” is not defined in the statute or elsewhere, its dictionary definition is “[t]o supply with necessities such as tools or provisions.” The American Heritage Dictionary of the English Language 602 (5th ed. 2018); Merriam-Webster’s Collegiate Dictionary 422 (11th ed. 2014) (defining “equip” to include “to furnish for service or action by appropriate provisioning”); see American Heritage, supra, at 712 (defining “furnish” and other synonyms of “equip” as “to provide with what is necessary for an activity or purpose” and providing examples of “furnished the team with new uniforms” and “equip a car with snow tires” ); see also Merriam-Webster’s, supra, at 508 (providing “furnish” as a synonym for “equip” and defining it as “to provide with what is needed”). Therefore, based on these dictionary definitions of “equipped,” its plain meaning is to supply or provide the necessities for a particular purpose."

*    *    *

"Appellant argues that “equipped” should be read to mean “if that component is presently attached to the vehicle,” such as a brake light, then that vehicle is “equipped” with that component. According to appellant, this definition is an “everyday life” and “natural use” of the word “equipped.” We disagree. This definition requires us to add the words to the statute. This we may not do."

"Accordingly, the deputy possessed a particularized and objective basis for suspecting appellant had committed a traffic violation based on his observation of appellant’s inoperable center brake light, thereby justifying the stop."

Moral Of The Story: It's lights out for the defendant!