The Minnesota DWI Case Of The Week is Obowa v. Commissioner of Public Safety, (Decided February 5, 2024, Minnesota Court of Appeals, Unpublished) which stands, once again, for the proposition that any vehicle equipment violation justifies the stop of the motor vehicle.
In Obowa, a law-enforcement officer with the Lino Lakes Public Safety Department was driving northbound on Lake Drive. A passenger vehicle was driving directly in front of the officer’s squad car. When the driver of the vehicle braked to stop for a red light, the officer observed that one of the vehicle’s brake lights was not working. The officer then initiated a traffic stop by pulling over the vehicle.
The officer spoke to the driver, James Obowa, and the officer could smelled the odor of alcohol, and observed Mr. Obowa exhibited bloodshot eyes and slurred speech. Further testing resulted in the arrest of Mr. Obowa for DWI and in the revocation of his driver's license.
Mr. Obowa challenged the license revocation but the district court sustained the revocation. On appeal, the Minnesota Court of Appeals affirmed the revocation, stating:
"A law enforcement officer may, however, consistent with the Fourth Amendment, conduct a brief, investigatory stop of a motor vehicle when the officer has a reasonable, articulable suspicion that criminal activity is afoot.” State v. Taylor, 965 N.W.2d 747, 752 (Minn. 2021) (quotation omitted). To satisfy the reasonable-suspicion standard, the officer “must articulate a particularized and objective basis for suspecting the particular person stopped of criminal activity.” State v. Timberlake, 744 N.W.2d 390, 393 (Minn. 2008) (quotation omitted)."
"In the traffic-stop context, the bar for reasonable suspicion is relatively low. See Taylor, 965 N.W.2d at 752, 757. “Generally, if an officer observes a violation of a traffic law, no matter how insignificant the traffic law, that observation forms the requisite particularized and objective basis for conducting a traffic stop.” State v. Anderson, 683 N.W.2d 818, 823 (Minn. 2004)."
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"Obowa challenges the district court’s determination that the officer had reasonable, articulable suspicion to support the traffic stop. More specifically, Obowa contends that the district court’s decision is based on a mistake of law and a mistake of fact because the record does not reflect that the officer had an objective basis to suspect that Obowa was operating his vehicle in violation of a traffic law. Based on our review of the applicable traffic laws and the record in this case, we are not persuaded."
"Minnesota law requires that a vehicle’s stop lamps and signal lamps “must at all times be maintained in good working condition.” Minn. Stat. § 169.57, subd. 3(a) (2022). In State v. Beall, we clarified that the statute “unambiguously applies to all lamps with which a vehicle is equipped.” 771 N.W.2d 41, 45 (Minn. App. 2009) (emphasis added). We concluded that “[a] vehicle with an inoperable [] brake light is operated unlawfully in violation of [section 169.57, subdivision 3(a)].” Id. And we held that an officer’s observation of a violation of that statutory provision “gives rise to objective, reasonable, articulable suspicion justifying a traffic stop.” Id.
"Beall instructs that an officer’s mere observation of an inoperable brake light is sufficient to justify a traffic stop. See id. That is exactly what the officer testified to in this case. At the implied-consent hearing, he stated that “when the vehicle applied its brakes, the driver’s-side brake light was inoperable.” This testimony is sufficient to support the traffic stop based on a violation of section 169.57, subdivision 3(a). We therefore conclude that the district court did not err in its determination that the officer had reasonable, articulable suspicion to stop Obowa."
Moral Of The Story: An ill equipped car is like living with a snitch.
If you or a loved one have been charged with a Minnesota DWI, feel free to contact Minnesota DWI Lawyer, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI and DUI questions.
