The Minnesota DWI Case Of The Week is State v. Payton (Decided November 18, 2024, Minnesota Court of Appeals, Unpublished) which stands for the proposition that the police will be believed without definitive proof to the contrary.
In Payton, the Defendant was arrested and charged with Third Degree DWI - Refusal to submit to testing. Mr. Peyton challenged the legality of the initial stop but the district court ruled that the stop was valid. On appeal, Mr. Peyton alleged the district court "clearly erred" when it ruled his vehicle crossed a white-dashed centerline without signaling, thereby giving the police officer reasonable, articulable suspicion to stop his vehicle.
The Minnesota Court of Appeals upheld the lower court's ruling stating:
"When reviewing a district court’s decision to deny a pre-trial suppression motion, we review the district court’s factual findings for clear error and legal determinations de novo. State v. Gauster, 752 N.W.2d 496, 502 (Minn. 2008). We 'will not conclude that a factfinder clearly erred unless, on the entire evidence, we are left with a definite and firm conviction that a mistake has been committed.' In re Civ. Commitment of Kenney, 963 N.W.2d 214, 221 (Minn. 2021)."
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"Here, the officer testified that he initiated a traffic stop because he observed Payton swerve 6-12 inches over the white-dashed centerline, without signaling, for 20-30 feet before recentering the vehicle in the appropriate lane. The officer indicated his belief that this conduct violated Minn. Stat. § 169.18, subd. 7(1), which states, “When any roadway has been divided into two [lanes] ... a vehicle shall be driven as nearly as practicable entirely within a single lane and shall not be moved from the lane until the driver has first ascertained that the movement can be made with safety.” The officer testified that he “clear[ly]” observed the violation and indicated exactly when the violation occurred in the dash-camera video. The district court found the officer’s testimony credible, and we defer to the district court’s credibility determinations. See State v. Smith, 448 N.W.2d 550, 555- 56 (Minn. App. 1989), rev. denied (Minn. Dec. 29, 1989). Based on this evidence, the district court found that Payton’s vehicle “swerve[d] and cross[ed] the dashed white line separating the two lanes without signaling.” We conclude that the evidence amply supports the district court’s finding that Payton crossed the white-dashed centerline without signaling."
"Payton disagrees, arguing the district court clearly erred when it found he crossed the white-dashed centerline. Payton relies on his assertion that the dash-camera video does not support the officer’s testimony. But contrary to Payton’s argument, though dark and poor quality, the dash-camera video does not contradict the officer’s testimony. While the white-dashed centerline does not appear in the dash-camera video, the dash-camera video plainly captures Payton’s vehicle veering slightly to the right at the time the officer testified that Payton crossed the white-dashed centerline. Although not dispositive, the dash-camera video bolsters the officer’s testimony that a traffic violation occurred."
"For these reasons, we conclude the district court did not clearly err when it found Payton crossed the white-dashed centerline without signaling and, thereby, violated Minn. Stat. § 169.18, subd. 7(1). As such, the district court correctly determined the officer had the requisite particularized and objective basis for conducting the traffic stop and, therefore, the investigatory stop was supported by reasonable, articulable suspicion."
Moral Of The Story: It's too bad that police cameras are far inferior to those used in viewing football.
If you or a loved one have been charged with a Minnesota DWI, feel free to contact Minneapolis DWI Attorney, F. T. Sessoms at (612) 344-1505 for answers to all of your Minnesota DWI and DUI questions.
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