State v. Yeargan
958 S.W.2d 626, 1997 Tenn. LEXIS 574, 1997 WL 724993 (1997)
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Rule of Law:
An officer's personal knowledge that a driver's license was recently revoked for a one-year period provides sufficient reasonable suspicion to conduct an investigatory traffic stop. The officer is not constitutionally required to exhaust less intrusive means, such as verifying the driver's license status, before initiating the stop.
Facts:
- Tullahoma Police Officer Jason Ferrell had previously arrested Wayne Lee Yeargan for driving under the influence (DUI).
- On July 2, 1992, Officer Ferrell was present in court when Yeargan pleaded guilty to DUI and his driver's license was revoked for a period of one year.
- On January 28, 1993, approximately six months later, Officer Ferrell observed Yeargan driving a pickup truck on a public street.
- As Officer Ferrell began to follow him, Yeargan accelerated and drove into the parking lot of a local bar.
- After the stop, Yeargan produced a restricted license permitting him to drive for employment purposes related to "farming" and being a "rental property owner."
- When asked why he was at the bar, Yeargan stated he was there to "meet a guy about a cow."
Procedural Posture:
- After his arrest, Wayne Lee Yeargan moved to suppress the evidence of his intoxication in the trial court, arguing the traffic stop was unconstitutional.
- The trial court denied the motion to suppress.
- Yeargan pleaded guilty to driving under the influence (second offense) and driving on a revoked license, but reserved the right to appeal a certified question of law regarding the constitutionality of the stop.
- Yeargan, as appellant, appealed to the Court of Criminal Appeals.
- The Court of Criminal Appeals affirmed the trial court’s decision, holding the officer had cause for an investigative stop.
- The Tennessee Supreme Court granted permission for Yeargan, as appellant, to appeal.
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Issue:
Does a police officer violate the state or federal constitutional right against unreasonable seizures by stopping a motor vehicle when the officer personally knows the driver's license had been revoked for one year approximately six months prior to the stop?
Opinions:
Majority - Drowota, J.
No. The stop does not violate the constitutional right against unreasonable seizures because it was based on reasonable suspicion supported by specific and articulable facts. An investigatory stop is a recognized exception to the warrant requirement, constitutionally permissible under Terry v. Ohio if an officer has a reasonable suspicion that a criminal offense has been committed. The officer’s personal knowledge that Yeargan’s license had been revoked for one year, with only six months having passed, constituted specific and articulable facts supporting a reasonable suspicion that Yeargan was committing the offense of driving on a revoked license. The mere possibility that Yeargan might have obtained a restricted license did not negate this reasonable suspicion. Furthermore, under United States v. Sokolow, the reasonableness of a stop does not depend on the availability of less intrusive investigatory techniques, so the officer was not required to verify the license status before making the stop.
Concurring - Reid, J.
No. The stop was constitutionally valid, but not because it met the standard for an investigatory stop; rather, it was justified by the higher standard of probable cause. The majority misinterprets Terry v. Ohio by failing to require exigent circumstances for a valid investigatory stop. The facts here—driving on a merely suspected revoked license—lacked the urgency or danger to the public needed to justify a Terry stop. However, the officer had probable cause to arrest because the officer's knowledge of the revocation, combined with Yeargan's furtive driving behavior and his presence at a bar (which is inconsistent with the likely terms of a restricted license for a farmer), was sufficient to warrant a prudent person's belief that Yeargan was committing an offense.
Analysis:
This case solidifies the principle that an officer's direct, personal knowledge is a powerful factor in establishing reasonable suspicion for a traffic stop. It clarifies that police are not required to rule out every possibility of innocence or use the least intrusive means available before conducting a Terry stop. The decision reinforces that the 'totality of the circumstances' is the controlling standard, and the potential for an exception to a law (like a restricted license) does not automatically defeat an officer's reasonable suspicion to investigate a likely violation.
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