People v. Taiwo

Defendant was convicted, after bench trial, of DUI, improper lane usage, and failure to notify authorities of an accident. Court properly allowed State's motion for directed finding pertaining to existence of probable cause and duration of traffic stop. Court properly allowed State's motion for directed finding pertaining to existence of probable cause and duration of this traffic stop. Thus, court properly denied motion to suppress, as court found that officer first observed a traffic violation before initiating the stop. In ruling on motion to quash arrest or suppress evidence, lawfulness of traffic stop,must be measured by trial judge, rather than dictated by officer's reasoning formulated under exigent circumstances. Circumstantial evidence supports finding that Defendant was in actual, physical control of vehicle before driver of another vehicle picked her up and offered her a ride home. Evidence was sufficient to establish Defendant's guilt of DUI beyond a reasonable doubt. (LYTTON and SCHMIDT, concurring.)