Joshua Banister v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMarch 7, 2024
Docket2022 CA 000596
StatusUnknown

This text of Joshua Banister v. Commonwealth of Kentucky (Joshua Banister v. Commonwealth of Kentucky) 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
Joshua Banister v. Commonwealth of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 8, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0596-DG

JOSHUA BANISTER APPELLANT

ON DISCRETIONARY REVIEW FROM v. MEADE CIRCUIT COURT HONORABLE BRUCE T. BUTLER, JUDGE ACTION NO. 21-XX-00003

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, CALDWELL, AND CETRULO, JUDGES.

ACREE, JUDGE: Joshua Banister, Appellant, appeals the Meade Circuit Court’s

April 29, 2022 Opinion Affirming the Meade District Court’s November 16, 2018

Order denying Appellant’s suppression motion. Appellant entered a conditional

guilty plea to appeal the denial of his motion, arguing a Kentucky State Trooper lacked the requisite reasonable suspicion of illegal activity when he observed

Appellant pulling a trailer on a public roadway with a woman riding on the trailer.

This Court granted discretionary review. We affirm.

BACKGROUND

On September 9, 2017, Trooper Richard Ellis encountered a GMC

Suburban pulling a trailer. He noticed a woman riding on the trailer rather than

within the safe confines of the vehicle and stopped the Suburban.

Trooper Ellis smelled a strong odor of alcohol when he approached

the vehicle. He administered field sobriety tests to Appellant who was driving the

Suburban. Testing revealed he was intoxicated. Trooper Ellis arrested Appellant

for driving under the influence of alcohol.

In the district court, Appellant filed a motion to suppress the evidence

of his offense arguing the female passenger riding in the trailer did not constitute a

violation of KRS1 189.125, Kentucky’s seatbelt statute. Accordingly, he argued,

Trooper Ellis did not have a reasonable and articulable suspicion of illegal activity

necessary to support the traffic stop. Following a suppression hearing, the district

court denied the motion. The court concluded the circumstances did support

Trooper Ellis’s reasonable and articulable suspicion sufficient to stop Appellant’s

1 Kentucky Revised Statutes.

-2- vehicle. The district court determined a person riding on a trailer constitutes a

violation of KRS 189.125(6).2 The appeal centers on this ruling.

ANALYSIS

Where, as here, there are no facts in dispute and the appeal raises only

legal questions, the appellate court undertakes a de novo review. In considering

the applicable law, we start with Appellant’s Fourth Amendment protections.

“In order to uphold the protections of the Fourth Amendment, an

officer conducting an investigatory stop must have a reasonable suspicion, based

on objective and articulable facts, that criminal activity has occurred, is occurring,

or is about to occur.” Commonwealth v. Morgan, 248 S.W.3d 538, 540 (Ky. 2008)

(footnote omitted) (citing Brown v. Texas, 443 U.S. 47, 51, 99 S. Ct. 2637, 2641,

61 L. Ed. 2d 357 (1979)).

As Appellant argues, Trooper Ellis could not have reasonably

suspected criminal activity was afoot because the seatbelt statute did not apply to

the woman who rode on Appellant’s trailer. Accordingly, Appellant and the

Commonwealth respectively urge us to define the scope of KRS 189.125 narrowly

or broadly. Appellant insists the statute does not apply to those riding in cargo

areas, such as a pickup bed or a trailer. The Commonwealth asserts that all

passengers must wear a seatbelt, no matter their location.

2 Procedurally, the case was a bit more circuitous, but in ways that do not affect the outcome.

-3- However, we need not determine this specific question. There is a

simpler and more direct resolution. “[R]easonable suspicion can rest on a mistaken

understanding of the scope of a legal prohibition . . . .” Heien v. North Carolina,

574 U.S. 54, 60, 135 S. Ct. 530, 536, 190 L. Ed. 2d 475 (2014). This is because

reasonableness is “the ultimate touchtone” of Fourth Amendment jurisprudence.

Id. (quoting Riley v. California, 573 U.S. 373, 381, 134 S. Ct. 2473, 2482, 189 L.

Ed. 2d 430 (2014)). “To be reasonable is not to be perfect, and so the Fourth

Amendment allows for some mistakes on the part of government officials[.]” Id. at

60-61, 135 S. Ct. at 536 (citing Brinegar v. United States, 338 U.S. 160, 176, 69 S.

Ct. 1302, 1311, 93 L. Ed. 1879 (1949)).

This extends to police officers’ reasonable suspicions: “Reasonable

suspicion arises from the combination of an officer’s understanding of the facts

and his understanding of the relevant law.” Id. at 61, 135 S. Ct. at 536. A police

officer may hold a “reasonably mistaken” understanding under either category. Id.

However, “[t]he Fourth Amendment tolerates only reasonable mistakes, and those

mistakes – whether of fact or of law – must be objectively reasonable.” Id. at 66,

135 S. Ct. at 539 (emphasis original).

Such objectively reasonable, but mistaken, understanding of law

existed in Heien, where a law enforcement officer pulled a driver over because one

of the driver’s brake lights was out. Id. at 57, 135 S. Ct. 534. But North Carolina

-4- law only required one of a vehicle’s brake lights to be functioning, not both. Id.

Though the statute required vehicles to be equipped with “a stop lamp” and not

two or more stop lamps, the statute provided that the stop lamp “may be

incorporated into a unit with one or more other rear lamps.” Id. at 59, 135 S. Ct. at

535 (quoting N.C. Gen. Stat. § 20-129(g) (2007)). Another provision of the statute

required that all vehicles “have all originally equipped rear lamps or the equivalent

in good working order[.]” Id. at 68, 135 S. Ct. at 540 (quoting N.C. Gen. Stat. §

20-129(d) (2007)). Accordingly, the Court found it reasonable to conclude that a

stop lamp is a type of rear lamp and, therefore, a vehicle equipped with multiple

stop lamps must have all stop lamps in working order. Id. at 67-68, 135 S. Ct. at

540. The Supreme Court had “little difficulty” in determining the officer held a

reasonable misunderstanding of the law. Id. at 67, 135 S. Ct. at 540.

It is not necessary to interpret the scope of KRS 189.125 to affirm the

district court. Assuming, arguendo, that Kentucky’s seatbelt statute did not require

passengers riding in trailers or in the beds of pickup trucks to wear seatbelts, it

would be completely reasonable for Trooper Ellis to have misunderstood the law to

prohibit individuals from riding in such areas without seatbelts. The seatbelt

statute, with narrow exceptions irrelevant to this appeal, states: “A person shall not

operate a motor vehicle manufactured after 1981 on the public roadways of this

state unless the driver and all passengers are wearing a properly adjusted and

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Related

Brinegar v. United States
338 U.S. 160 (Supreme Court, 1949)
Brown v. Texas
443 U.S. 47 (Supreme Court, 1979)
Commonwealth v. Morgan
248 S.W.3d 538 (Kentucky Supreme Court, 2008)
Riley v. Cal. United States
134 S. Ct. 2473 (Supreme Court, 2014)
Heien v. North Carolina
135 S. Ct. 530 (Supreme Court, 2014)

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Joshua Banister v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joshua-banister-v-commonwealth-of-kentucky-kyctapp-2024.