Earlier this year, a state appellate court issued an opinion in a Michigan drunk driving case discussing the defendant’s challenges to his conviction. However, after reviewing and rejecting each of the defendant’s arguments, the court affirmed his conviction. That said, the case is important, as it illustrates the type of challenges that may be successful, especially pertaining to field sobriety tests.
The Facts of the Case
According to the court’s opinion, a Michigan State Police Trooper observed the defendant not maintaining his lane. The Trooper pulled up next to the defendant, saw that he was not distracted or on his phone, and initiated a traffic stop. Upon approaching the defendant, the Trooper noticed that the defendant’s eyes were watery and smelled like alcohol. The defendant explained he had two martinis and was on his way home.
The Trooper then administered three field sobriety tests (FSTs), a horizontal gaze nystagmus test, the walk-and-turn test, and the one-leg stand test. After determining that the defendant exhibited signs of intoxication, the Trooper arrested him.
In a pre-trial motion, the defendant challenged the admissibility of the FSTs. Specifically, the defendant claimed that what appeared to be signs of intoxication were attributable to a medical condition. In support of his position, the defendant presented the testimony of an expert witness who testified that, in addition to the defendant’s medical issues, the presence of traffic and the Trooper’s bright flashlight might have further contributed to what the Trooper mistook for signs of intoxication. The trial court denied the defendant’s motion, which he appealed.
On appeal, the trial court affirmed the denial of the defendant’s motion to suppress. The court explained that an officer must have probable cause to arrest someone for drunk driving. The administration of FSTs can provide probable cause, assuming they are correctly administered. However, the court also noted that it is to consider the “totality of the circumstances” when reviewing a defendant’s challenge to FSTs.
Here, the court determined that the FSTs were not improperly performed and that the defendant failed to show that the results were unreliable. The court explained that the Trooper was not required to rule out all innocent explanations of a defendant’s poor performance on FSTs – such as medical issues – and that these went not to the admissibility of the FSTs, but to the weight the fact-finder afforded them. Thus, the court affirmed the defendant’s conviction.
Have You Been Arrested for Michigan DUI?
If you were recently arrested for a Michigan drunk driving offense, reach out to the dedicated criminal defense attorneys at the Michigan Defense Law. Our skilled defense attorneys have extensive experience defending the rights of those accused of serious crimes, including DUI offenses. We understand how stressful it is to have criminal charges hanging over your head, and take every step to put your mind at ease throughout the process. With us in your corner, you can rest assured that you are in good hands. To learn more, and to schedule a free consultation today, call 248-451-2000.