Summary
The Michigan Supreme Court held that a towing ball partially obstructing a vehicle’s registration plate violated MCL 257.225(2), which requires a plate to be attached in a clearly visible position. The traffic stop was therefore lawful, and the trial court properly denied the defendant’s motion to suppress contraband discovered during the ensuing vehicle search.
Topics
Practice areas
Questions Presented
- Whether a towing ball attached to a vehicle that partially obstructs its registration plate violates MCL 257.225(2).
- Whether the alleged registration-plate violation provided a lawful basis for the traffic stop.
- Whether the trial court properly denied defendant's motion to suppress the contraband as fruit of an unlawful seizure.
Holdings
- The second sentence of MCL 257.225(2) requires a registration plate and surrounding attachments to be configured so that the plate is not partially or fully obstructed. An attached towing ball that obstructs the plate violates the statute.
- Because defendant violated MCL 257.225(2), the officers had a lawful basis to stop his vehicle.
- Suppression was properly denied because the stop was lawful; the contraband discovered after the officers smelled burnt marijuana was not fruit of an unlawful seizure.
Key quotations
“We conclude that the second sentence of MCL 257.225(2) requires a vehicle’s registration plate and surrounding attachments to be configured in such a manner that the plate is not partially or fully obstructed.” (73)
“The statute therefore prohibits a registration plate from being obstructed by an object attached to a vehicle.” (73)
“Because MCL 257.225(2) prohibits an obstruction of a vehicle’s registration plate, defendant violated the statute.” (71)
Factual background
Police officers followed defendant's pickup truck and observed that a bumper-mounted towing ball partially obstructed the vehicle's registration plate. The officers stopped the truck for the alleged registration-plate violation, then smelled burnt marijuana and searched the vehicle, finding marijuana, cocaine, and a handgun. Defendant was charged with possession of cocaine, possession of marijuana, and carrying a concealed weapon.
Procedural history
After police stopped defendant for a partially obstructed registration plate and discovered marijuana, cocaine, and a handgun during a vehicle search, defendant moved to suppress the evidence as fruit of an unlawful seizure. The trial court denied the motion. The Michigan Court of Appeals reversed in a split decision. The Michigan Supreme Court, in lieu of granting leave to appeal, reversed the Court of Appeals, reinstated the suppression ruling, and remanded for further proceedings.
Remand instructions
Reverse the Michigan Court of Appeals' judgment, reinstate the trial court's denial of defendant's motion to suppress, and remand to the trial court for further proceedings.