People v. Hackett
2012 IL 111781, 971 N.E.2d 1058 (2012)
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Rule of Law:
A police officer has reasonable, articulable suspicion to conduct an investigatory traffic stop when they observe a driver deviate from their lane of traffic twice for no apparent reason.
Facts:
- On August 19, 2008, Dennis Hackett was driving his GMC pickup truck northbound on Briggs Street in Joliet, Illinois.
- Will County Deputy Michael Blouin was in his squad car, following directly behind Hackett's truck.
- Hackett's truck was traveling in the left of two northbound lanes.
- Deputy Blouin observed both of Hackett's right-side tires cross over the striped line separating the left and right lanes.
- Hackett's truck then returned fully to the left lane.
- Approximately four or five seconds later, Deputy Blouin observed Hackett's truck do the exact same thing again.
- Deputy Blouin did not observe any potholes, obstructions, or other road conditions that would have made it necessary for Hackett to swerve.
- After the second deviation, Hackett made a left turn, and Deputy Blouin initiated a traffic stop.
Procedural Posture:
- Dennis Hackett was charged in the Circuit Court of Will County with aggravated driving under the influence of alcohol and aggravated driving while license revoked.
- Hackett filed a motion to quash arrest and suppress evidence in the circuit court, arguing the arresting officer lacked legal justification for the initial traffic stop.
- The circuit court (trial court) granted Hackett's motion, finding that the 'momentary crossings' of the lane line did not provide reasonable grounds for the stop.
- The State, as appellant, appealed the trial court's decision to the Appellate Court of Illinois, Third District.
- A divided appellate court affirmed the circuit court's ruling, with Hackett as the appellee.
- The State, as appellant, then filed a petition for leave to appeal to the Supreme Court of Illinois, which the court granted.
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Issue:
Does a police officer have a reasonable, articulable suspicion to conduct an investigatory traffic stop when the officer observes a driver's vehicle cross over the lane line twice for no apparent reason?
Opinions:
Majority - Justice Karmeier
Yes, a police officer has reasonable, articulable suspicion for an investigatory stop in these circumstances. An investigatory stop is justified by the less exacting standard of 'reasonable, articulable suspicion,' not the higher standard of probable cause. The relevant statute, section 11-709(a), requires a vehicle to be driven 'as nearly as practicable' within a single lane. When an officer observes multiple lane deviations for no obvious reason, such as weather or road obstructions, those observations constitute specific and articulable facts that warrant an investigatory stop. The purpose of such a stop is to allow the officer to investigate the reason for the erratic driving. The court clarified that while probable cause for a conviction under the statute would require proof that it was 'practicable' for the driver to stay in the lane, an officer does not need to satisfy every element of the offense to have reasonable suspicion for a stop. The appellate court erred by inventing a requirement that a driver must travel in another lane for a 'reasonably appreciable distance,' as no such requirement exists in the statute.
Analysis:
This decision clarifies the standard for traffic stops based on improper lane usage in Illinois, solidifying that 'reasonable suspicion' is the appropriate standard for an initial investigatory stop. It distinguishes this lower standard from the 'probable cause' required for an arrest, providing law enforcement with clear authority to stop vehicles that exhibit erratic driving without first having to disprove all possible innocent explanations. By rejecting the appellate court's 'appreciable distance' test, the court reinforced a plain-language reading of the statute, making it easier for officers to initiate stops to investigate potential driver impairment, distraction, or medical emergencies based on otherwise unexplained lane deviations.
