Commonwealth of Kentucky v. William Michael McCuiston

CourtCourt of Appeals of Kentucky
DecidedJanuary 23, 2026
Docket2024-CA-1109
StatusPublished

This text of Commonwealth of Kentucky v. William Michael McCuiston (Commonwealth of Kentucky v. William Michael McCuiston) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth of Kentucky v. William Michael McCuiston, (Ky. Ct. App. 2026).

Opinion

RENDERED: JANUARY 23, 2026; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-1109-DG

COMMONWEALTH OF KENTUCKY APPELLANT

ON REVIEW FROM CALLOWAY CIRCUIT COURT v. HONORABLE ANDREA L. MOORE, JUDGE ACTION NO. 23-XX-00001

WILLIAM MICHAEL MCCUISTON APPELLEE

OPINION REVERSING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; EASTON AND L. JONES, JUDGES.

EASTON, JUDGE: In this driving under the influence (DUI) of alcohol case, the

Calloway District Court denied the Appellee’s (McCuiston) motion to suppress

evidence. McCuiston entered a conditional guilty plea. The Calloway Circuit

Court reversed. We granted discretionary review. Because the Calloway Circuit

Court erred by failing to accept the factual findings of the district court as well as by misapplication of the law, we reverse the circuit court and reinstate the district

court’s judgment.

FACTUAL AND PROCEDURAL BACKGROUND

In the early morning hours of October 29, 2022, Officer Griffin Deese

(Deese) with the Murray City Police Department responded to a report of shots

fired near Tap 216, a local bar in Murray, Kentucky. As Deese investigated, it

became clear that the report probably resulted from some other noise in the

vicinity, and no criminal activity was ever determined to have occurred.

Deese was wearing a body camera that night. While Deese spoke

with employees outside of Tap 216 about the shots-fired report, the camera was

facing the employees and the entrance of the bar. An exchange among the

employees and Deese about McCuiston changed the focus of the police activity

from the shots-fired report to an eventual DUI arrest.

McCuiston exited the bar. As McCuiston got into his vehicle, the

employees made the following statements referring to McCuiston: “Oh, he better

not be. Ah, don’t do it dude. S***, you f***ing fool.” Deese asked the

employees: “Has he been drinking?” One employee says, “Yeah” followed

-2- immediately by another employee saying, “Yeah, a lot.”1 Deese testified that he

saw McCuiston stumble while in the parking lot.2

Deese can be seen entering his police vehicle to follow McCuiston.

As he started to follow McCuiston, Deese called in to his dispatcher saying,

“behind a possible intoxicated driver.”3 Deese did not remember whether

McCuiston gave a turn signal as he turned out of the Tap 216 parking lot and

eventually onto University Drive. There was no dash camera recording, and the

body camera showed only the steering wheel while Deese drove.

University Drive is a two-lane road that oddly becomes four lanes as it

intersects with 16th Street. We have created a composite drawing based on

photographs in the record. This drawing may not be to perfect scale, but it should

assist in understanding this intersection. We have attached the drawing as an

appendix to this Opinion.

1 This conversation appears at the Video Record (VR) for January 25, 2023, at 9:35:00 – 9:35:50. 2 The body camera video was recorded at night and is somewhat grainy. We can see McCuiston walking on the video, and, while we see his slow or perhaps uncertain gait as he left the bar, we cannot see all the way until McCuiston got into his vehicle because of a movable fence gate and a vehicle partially blocking the view. The body camera was pointed in the direction Deese’s torso was facing as he interacted with the employees. This does not mean that Deese did not look over and see McCuiston “stumble.” At any rate, such a factual finding was for the district court to make, not the circuit court, depending on whether the district court judge believed Deese. 3 VR, January 25, 2023, at 9:36:50.

-3- As the single westbound lane of University Drive approaches 16th

Street, that lane is split by a grassy area. The driver must continue to his right or

veer to the left. If the driver veers to the left, then another, smaller grassy area

splits that lane again to allow a left turn onto southbound 16th Street. This second

split also allows for a left turn off southbound 16th Street to go eastbound on

University Drive. Such a driver would have to yield before crossing the remaining

westbound lane of University Drive to travel eastbound. The opposite, eastbound

lane of University Drive enters off northbound 16th Street as a right turn. In effect,

this double “Y” intersection is a modified split “T” intersection of University Drive

and 16th Street.

McCuiston stayed in the westbound lane from the time he entered

University Drive until he got to the stop sign to turn right onto northbound 16th

Street. Although McCuiston eventually used a turn signal, he argues he was not

required to signal when his lane first split nor as he reached the stop sign, because

the lane he stayed in became a right-turn-only lane. The only marking on the lane

where McCuiston eventually stopped is a single, short right-turn arrow at the end

(not the typical long arrow, series of arrows, or other markings indicating a turn-

only lane).

Deese can be heard on his radio with another officer offering to assist

him. Deese responds: “That’s okay. He just didn’t use his turn signal right here.

-4- So, he’s about to get pulled over.”4 Deese testified that he eventually saw

McCuiston use a signal, but the signal was not used for a continuous 100 feet

before the stop and turn. McCuiston to some extent would confirm that

observation. When pulled over, McCuiston said that he used his right-turn signal,

but it deactivated as he veered to the right. He said he then turned it back on.

Upon approaching McCuiston, Deese smelled alcohol and noticed

McCuiston’s red eyes, which McCuiston blamed on allergies. Deese also noticed

repetition and slurred speech. Further steps in the DUI investigation, including

failed field sobriety tests, led to McCuiston’s arrest. His blood alcohol content

(BAC) measured .129. McCuiston was arrested and charged with Operating a

Motor Vehicle Under the Influence of Alcohol in violation of KRS5

189A.010(1)(a), and “Failure to or Improper Signal” in violation of KRS 189.380.

McCuiston filed a motion to suppress in the district court, challenging

the traffic stop. He argued there was no duty to use a turn signal because he stayed

in the eventual turn-only lane as he approached the intersection. McCuiston relied

heavily on a 2011 Calloway Circuit Court decision6 in a prior, unrelated case

involving a different intersection. In this prior decision, the circuit court found the

4 VR, January 25, 2023, at 9:37:42. 5 Kentucky Revised Statutes. 6 Calloway Circuit Court Case No. 11-XX-00001, Order entered June 23, 2011, TR at 29.

-5- basis of a traffic stop insufficient where the driver failed to use a right-turn signal

when he turned right from a right-turn-only lane.

Similarly, McCuiston maintains that he was traveling in one lane

toward 16th street and never moved out of his lane of travel before reaching the

stop sign. As a result, he argues he had no duty to use a turn signal at any point

prior to his turn onto 16th Street (which begs the question of why he admitted

using one repeatedly). McCuiston also disputed that he failed to use his turn signal

continuously for at least 100 feet prior to reaching the stop sign at 16th Street.

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