State v. Dalton

165 N.H. 263 (2013) · Supreme Court of New Hampshire · August 21, 2013

Summary

The New Hampshire Supreme Court affirmed Bradford Dalton’s conviction for third-offense driving under the influence. The court held that an officer’s request for the defendant’s license, registration, and inspection paperwork was reasonably related to a traffic stop initiated because the officer could not determine whether the vehicle’s transparent temporary inspection sticker was valid.

Holdings

  1. The officer's request for Dalton's license, registration, and inspection paperwork was reasonably related to the initial justification for the stop and was a permissible routine component of the motor vehicle stop.
  2. The Federal Constitution provided no greater protection than Part I, Article 19 of the New Hampshire Constitution in this area, so the result was the same under both constitutions.

Questions Presented

  1. Whether the officer unconstitutionally continued the motor vehicle stop after observing a transparent temporary inspection sticker.
  2. Whether the officer's request for Dalton's license, registration, and inspection paperwork was reasonably related to the initial justification for the stop under Part I, Article 19 of the New Hampshire Constitution and the Fourth and Fourteenth Amendments to the United States Constitution.

Disposition

affirmed

Cases Cited (12)

  • State v. Schultz, 164 N.H. 217, 221 (2012)(followed)
  • State v. Ball, 124 N.H. 226, 231-33 (1983)(followed)
  • State v. Licks, 154 N.H. 491, 492-93, 495 (2006)(followed)
  • Terry v. Ohio, 392 U.S. 1, 21 (1968)(followed)
  • State v. Bell, 164 N.H. 452, 454 (2012)(followed)
  • State v. Smith, 154 N.H. 113, 116 (2006)(followed)
  • United States v. Jenkins, 452 F.3d 207, 213 (2d Cir. 2006)(not followed)
  • State v. McKinnon-Andrews, 151 N.H. 19, 25 (2004)(followed)
  • Delaware v. Prouse, 440 U.S. 648, 658 (1979)(followed)
  • State v. Glaude, 131 N.H. 218, 222 (1988)(followed)

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