Motor Vehicle Admin. v. Lipella
Annotate this CaseAfter a sheriff's deputy pulled Ronald Lipella over for swerving outside the proper travel lane on a county highway, the deputy administered to Lipella three standard field sobriety tests, all of which Lipella failed. An ALJ subsequently suspended Lipella's driver's license was subsequently for driving while intoxicated. The circuit court held that the ALJ's suspension of Lipella's license was unsupported by substantial evidence, concluding that the deputy failed to indicate adequately on the Motor Vehicle Administration (MVA) Form DR-15A the reasonable grounds for the underlying traffic stop that led to the license suspension. The Court of Appeals reversed the circuit court, holding (1) the Implied Consent Statute does not require the officer to supply the grounds for the underlying traffic stop, but rather, the officer is required to provide on the DR-15A form the reasonable grounds for the suspect's intoxication; and (2) thus, the ALJ concluded properly that the MVA mounted successfully a prima facie case, which was unrebutted, supporting the suspension of Lipella's license.
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