Catrena Green v. Adam Throckmorton, No. 10-4487 (6th Cir. 2012)
Annotate this CaseFollowing a traffic stop for failing to dim her high beams in the face of oncoming traffic, Green was arrested for driving under the influence of drugs or alcohol, based on her responses to a series of field sobriety tests administered by a state trooper. A more definitive test, her urine sample, later came back clean; all charges were dropped. Green sued under 42 U.S.C. 1983, alleging that the trooper violated her Fourth Amendment rights by conducting field sobriety tests without having a reasonable suspicion that she was impaired and arresting her without probable cause. The district court dismissed. The Sixth Circuit reversed. A reasonable jury could find that Green's conduct did not create a reasonable suspicion that she was driving under the influence, that Green acted rationally throughout the stop, that her relatively minor traffic violations were not indicative of impairment, and that the officer fabricated the alleged constriction of her pupils to create an after-the-fact justification for the detention.
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