State v. Eckblad, 152 Wash. 2d 515

Summary

The Washington Supreme Court considered whether Washington's seat belt statute, RCW 46.61.688, was unconstitutionally vague. The court held that the statute was not facially vague or vague as applied to Trevor Eckblad's case, reversed the suppression order, and remanded for further proceedings. The court cautioned that the statute could potentially be vague as applied in a different case involving a reasonable belief that a vehicle or occupants were exempt.

Holdings

1. RCW 46.61.688 is not facially void for vagueness.
2. Eckblad did not establish that RCW 46.61.688 was unconstitutionally vague as applied to the facts of his case.
3. Because the seat-belt statute was not vague facially or as applied to Eckblad, the trial court's suppression and dismissal rulings could not stand; the judgment was reversed and the matter remanded for further proceedings.

Questions Presented

1. Whether RCW 46.61.688 is facially unconstitutionally vague because it incorporates federal seat-belt standards and contains exemptions.
2. Whether RCW 46.61.688 is unconstitutionally vague as applied to Eckblad's circumstances.
3. Whether the evidence obtained following the seat-belt stop should be suppressed as fruit of an illegal stop.

Disposition

reversed_and_remanded