Summary
Aaron Noteboom appealed his conviction for driving under the influence, arguing that the investigatory stop of his vehicle violated the Fourth Amendment and the South Dakota Constitution. The Supreme Court of South Dakota held that, under the totality of the circumstances, the officers had reasonable suspicion to conduct the stop and affirmed the conviction.
Topics
Practice areas
Questions Presented
- Whether the officers had reasonable suspicion under the Fourth Amendment and the South Dakota Constitution to stop Noteboom's vehicle.
- Whether the stop, detention, and subsequent search violated Noteboom's constitutional rights.
Holdings
- The stop was constitutionally permissible because, considering the totality of the circumstances, the officers had a specific and articulable, though minimal, objective basis to suspect that criminal activity might be afoot.
- The circuit court properly denied the motion to suppress because the stop did not violate Noteboom's constitutional rights.
Key quotations
“Although these circumstances constitute a minimal objective justification for an investigatory stop, we determine they are reasonable under the totality of the circumstances.” (¶ 13)
Factual background
At approximately 2:00 a.m., officers saw automobile headlights appear and disappear near a storage area on private property in Corsica, South Dakota. Deputy Strid followed fresh tire tracks onto the property and observed a vehicle parked behind a building with its headlights off; when the vehicle's headlights came on and it began to leave, Chief Banghart stopped it. The officers acknowledged that Noteboom had committed no traffic or vehicle violation, but after the stop Banghart observed that Noteboom was intoxicated and arrested him for driving under the influence.
Procedural history
Deputy sheriffs stopped Noteboom after observing a vehicle enter private storage property at approximately 2:00 a.m., remain there with its headlights off, and abruptly leave when an officer approached. The circuit court denied Noteboom's suppression motion, found the stop constitutional, and convicted him of driving under the influence of alcohol. The South Dakota Supreme Court affirmed.