People v. Gutierrez and People v. Carrillo-Toledo

Summary

The Colorado Supreme Court held that section 42-4-903(4), C.R.S. (2019), requires a driver to activate a turn signal before beginning a lane change. Because the officer reasonably suspected a traffic violation after observing the vehicle move partially into another lane before signaling, the traffic stop was lawful under the Fourth Amendment. The court reversed the trial court’s suppression order and remanded for further proceedings.

Holdings

1. An interlocutory appeal filed within the applicable deadline is timely even when mistakenly filed in the wrong appellate court and later transferred to the court with jurisdiction.
2. Section 42-4-903 requires a driver to activate a turn signal before beginning a lane change; a driver may not simultaneously signal and move into another lane. Because the officer observed the truck partially cross the lane-dividing line before the signal was activated, he had an objectively reasonable basis to believe a traffic violation had occurred and lawfully stopped the vehicle.

Questions Presented

1. Whether the prosecution's interlocutory appeal was timely when it was filed within the statutory period in the wrong appellate court and later transferred to the Colorado Supreme Court.
2. Whether Colorado Revised Statutes section 42-4-903(4) requires a driver to activate a turn signal before beginning a lane change.
3. Whether the officer had an objectively reasonable basis to stop the vehicle based on the observed lane-change violation.

Disposition

reversed_and_remanded