State v. Redding

Summary

The Montana Supreme Court affirmed the denial of Clay David Redding's motions to dismiss and suppress evidence in a DUI case. The court held that officers had sufficient grounds to detain and charge Redding, that photographs of open beer containers in plain view were admissible, and that evidence of his refusal to submit to a breath test was admissible because the implied-consent form had been read to him.

Holdings

1. The officers had ample reason to respond to and investigate the situation, sufficient cause to detain Redding long enough to determine whether he would provide a breath sample, and probable cause to charge him based on the officers' observations at the scene.
2. Field sobriety tests are not required before bringing a DUI charge, and the failure to administer them does not constitute a due process or statutory violation.
3. Photographs of the open beer can and open beer box were admissible because the items were concededly in plain and open view and subject to seizure as evidence.
4. Redding's refusal to take the breath test was admissible because the District Court found that officers read the complete implied-consent form to him.

Questions Presented

1. Whether the officers had probable cause to arrest or charge Redding with DUI despite his alternative explanations for his condition.
2. Whether the officers had sufficient cause to detain Redding long enough to request a breath sample.
3. Whether the absence of field sobriety tests required dismissal of the DUI charge or suppression of the evidence.
4. Whether photographs of the open beer can and open beer box were unlawfully seized despite their presence in plain view.
5. Whether Redding's refusal to submit to a breath test was inadmissible because the officers allegedly failed to read the complete implied-consent form.

Disposition

affirmed