Michigan v. Lucynski (Opinion - Leave Granted)

David Lucynski was charged with operating a vehicle while intoxicated (OWI); driving with a suspended license; and operating a vehicle with an open container of alcohol in the vehicle. The officer in this case claimed that he followed defendant because he believed defendant committed a traffic violation that would have justified the subsequent seizure, questioning, search, and arrest. The district court held there was no traffic violation, that the seizure was unconstitutional, that defendant would not be bound over for operating while intoxicated (OWI), and that the unlawfully obtained evidence had to be suppressed. The prosecution argued that a “reasonable mistake” occurred as to the traffic violation, that suppression of the evidence was not required, and that the bindover decision was incorrect. The Court of Appeals agreed and further held that defendant had not been seized until after he made incriminating statements, and thus the district court erred. After its review, the Michigan Supreme Court held that defendant was seized under the Fourth Amendment when the officer blocked the driveway and defendant’s path of egress with a marked patrol car because, under the totality of the circumstances, a reasonable person would not have felt free to leave or to terminate the interaction. Second, the “impeding traffic” statute at issue, MCL 257.676b(1), is only violated if the normal flow of traffic is actually disrupted. Third, the officer’s mistaken reading of this unambiguous statute was not objectively reasonable, and thus no reasonable mistake of law occurred. Accordingly, the Supreme Court reversed the Court of Appeals and remanded this case to that court to determine whether application of the exclusionary rule was the appropriate remedy for the violation of defendant’s Fourth Amendment rights.