State v. Trombley

Summary

The Montana Supreme Court held that a police officer had particularized suspicion to conduct an investigatory traffic stop after observing the defendant make an erratic U-turn, drift over the fog line, straddle the center line, and fail to signal. The court affirmed the district court’s decision upholding the municipal court’s denial of the defendant’s motion to dismiss.

Holdings

1. The officer had the requisite particularized suspicion to conduct an investigatory stop because the totality of the circumstances, including Trombley's drifting over the fog line, straddling the center line, erratic lane movement, and failure to signal, supplied objective data from which the officer could infer that Trombley was engaged in wrongdoing.
2. An officer's mistaken belief that a U-turn violated state law does not invalidate an investigatory stop when other observed circumstances independently establish particularized suspicion.

Questions Presented

1. Whether the District Court properly affirmed the Municipal Court's denial of Trombley's motion to dismiss for lack of particularized suspicion.
2. Whether an officer's mistaken belief that Trombley's U-turn was illegal rendered the investigatory stop unlawful despite other observed erratic driving.

Disposition

affirmed