Summary
The Vermont Supreme Court affirmed the denial of Kurt Williams's motion to suppress evidence obtained following a DUI checkpoint stop. The court held that the checkpoint's staffing deviation from state police guidelines did not render the checkpoint unconstitutional because the guidelines concerned vehicle-selection procedures, the checkpoint operated on a systematic basis, and Williams failed to establish a causal nexus between the deviation and the evidence sought to be suppressed.
Topics
Practice areas
Questions Presented
- Whether operating a DUI checkpoint with four troopers, contrary to a state police guideline calling for at least five troopers when traffic is stopped in both directions, rendered the checkpoint unconstitutional.
- Whether the alleged staffing-guideline violation justified suppression of the evidence because it affected police discretion in selecting vehicles or had a causal nexus to the evidence obtained from Williams.
Holdings
- A deviation from a checkpoint staffing guideline does not necessarily make a DUI checkpoint unconstitutional when the deviation does not regulate or affect the manner in which vehicles are selected for stopping and the checkpoint otherwise operates on a systematic, nonrandom basis.
- Suppression requires the defendant to establish a causal nexus between the alleged constitutional illegality and the evidence sought to be suppressed; Williams failed to establish that nexus.
Key quotations
“Read together, the two criteria are intended to "carefully circumscribe" police discretion in the stopping of vehicles, rather than regulate discretion as to how many troopers to have on the scene.” (242, ¶ 9)
“For suppression to be granted based on an alleged constitutional violation, a "causal nexus must exist between the alleged illegality and the evidence" that a defendant seeks to suppress.” (242, ¶ 10)
Factual background
On March 29, 2006, Vermont State Police established a DUI checkpoint on Route 100 in Weston, stopping vehicles traveling in both directions. Six troopers were present when the checkpoint began, but two left with individuals arrested for DUI, leaving four troopers operating the checkpoint when Williams was stopped. Williams was subsequently asked to perform field sobriety tests and provide a preliminary breath sample, was taken into custody, and the checkpoint was ended after only three troopers remained.
Procedural history
Williams was stopped at a DUI checkpoint and later charged with DUI. Following a joint suppression and civil-suspension merits hearing, the trial court denied his motion to suppress, finding that operation of the checkpoint with four rather than five troopers was not so unreasonable as to make the checkpoint unconstitutional. Williams entered a conditional guilty plea and appealed.