State of Indiana v. Michael Dwayne Bouye
State of Indiana v. Michael Dwayne Bouye
Opinion
*24 [1] The State appeals the trial court's order granting Michael Bouye's motion to suppress, arguing that the arresting officer had reasonable suspicion to stop Bouye's vehicle. Finding that there was reasonable suspicion, we reverse and remand for further proceedings.
Facts
[2] On April 8, 2017, Indianapolis Metropolitan Police Department (IMPD) Officer Ross Jette was driving down 38 th Street in Indianapolis. At approximately 2:42 a.m., he conducted a license plate check using the Indiana Data and Communication System (IDACS) of a 2000 white Saturn driving directly in front of him. The database search showed that the license plate was registered for a different vehicle: a 2005 Jeep Renegade. Officer Jette ran the same check again to verify his findings, and the search returned the same result.
[3] Officer Jette then conducted a traffic stop of the white Saturn, believing that the driver (Bouye) was improperly operating a vehicle with a license plate belonging to a different vehicle. 1 Sometime during the stop, Officer Jette discovered marijuana and noticed that Bouye was possibly intoxicated. Appellant's App. Vol. II p. 14-16. Officer Jette arrested Bouye.
[4] Later that day, the State charged Bouye with one count of Class A misdemeanor possession of marijuana, one count of Class C misdemeanor operating a vehicle while intoxicated, and one count of Class C misdemeanor operating a motor vehicle with an A.C.E. of .08 or more. Bouye moved to suppress the evidence, alleging that Officer Jette did not have reasonable suspicion to stop his vehicle and that all evidence attained from the stop should be excluded.
[5] At the June 26, 2018, suppression hearing, Bouye's wife testified that she was the owner of the 2000 white Saturn that Bouye was driving on the night of the incident. She also testified that she purchased the vehicle on March 1, 2017, and that one day later, she registered the vehicle with the Bureau of Motor Vehicles (BMV). After selling her 2005 Jeep Renegade, she transferred its license plate to the couple's 2000 white Saturn and re-registered the plate with the BMV as well. Bouye's wife presented the registration receipt to prove that the 2005 Jeep Renegade plate was properly registered with the 2000 white Saturn on March 2, 2017, more than one month before Bouye's arrest.
[6] The trial court granted Bouye's motion to suppress all evidence obtained as a result of the stop, holding that there was a "breakdown somewhere" that misled Officer Jette and that he did not have a reasonable suspicion to stop the vehicle. Tr. Vol. II p. 22-23. The State now appeals.
Discussion and Decision
[7] On appeal, the State argues that the motion to suppress should be reversed, claiming that Officer Jette had the reasonable suspicion necessary to stop Bouye's vehicle.
[8] The State is appealing from a negative judgment,
2
so it has the burden to show that the trial court's ruling on the suppression motion was contrary to law.
State v. Brown
,
[9] A routine stop for a suspected traffic violation constitutes a seizure of the vehicle and its occupants under the Fourth Amendment to the United States Constitution.
Clarke v. State
,
[10] Here, Officer Jette conducted a routine IDACS search of a license plate right in front of him. After the search showed that the plate was registered to another vehicle, he ran the search again to verify the results. When the results showed the same information, Officer Jette reasonably believed that the driver of the 2000 white Saturn was improperly driving a vehicle without the correct license plate, a violation of Indiana law. We have held before that such routine license plate checks showing potential improper plate registration are enough to create a reasonable suspicion.
See
Smith v. State
,
[11] The fact that Bouye's wife, at the suppression hearing, proved that Bouye had not violated the law regarding the license plate and that the plate was, in fact, registered with the correct vehicle is beside the point. Even if it is later shown that the defendant did not violate the law, the stop itself is still constitutional so long as the officer had a reasonable suspicion that a violation had occurred.
See
Sanders
,
[12] We also note that the trial court seemed to impose a requirement that an officer search multiple databases before stopping a vehicle, stating that "if the officer would have [also] checked the BMV
*26 records, it would have showed that the license plates were properly registered with the BMV." Supp. Tr. Vol. I p. 4-5. The trial court found that Officer Jette improperly relied on IDACS alone to conduct his search when additional searches in other databases would have led him to the correct conclusion. Officer Jette was not required to conduct a full investigation of the white Saturn in front of him. Rather, he appropriately ran two routine searches on IDACS, and when the license plate discrepancy was revealed, he stopped the vehicle. Despite the trial court's statements, Officer Jette was under no obligation to do more than the IDACS search to establish a reasonable suspicion. Moreover, even if Officer Jette had searched the BMV records, he would have discovered a discrepancy between the BMV and the IDACS. That, too, would have provided him with reasonable suspicion of a violation. In any event, this was an improper reason to grant Bouye's motion to suppress. Therefore, we reverse and remand.
[13] The judgment of the trial court is reversed and remanded for further proceedings.
May, J., and Tavitas, J., concur.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.