Washington v. Brown (Majority)
Annotate this CaseBecause respondent David Brown did not signal continuously while his vehicle turned left through an intersection, he violated RCW 46.61.305. State patrol officers observed Brown turn right onto a four-lane street. While turning, the left side tires of Brown’s truck briefly crossed the white dashed divider line before moving back to the correct lane. Eventually, Brown activated his turn signal and moved his truck left while the signal blinked a few times before shutting off. Officers driving behind Brown initiated a traffic stop; a breath test was administered, and Brown was found to have had a 0.26 breath alcohol content. In court, Brown moved to suppress the evidence gathered during the traffic stop. The State argued violation of RCW 46.61.305 was grounds for the stop. The trial court concluded a driver was not required to reactivate his turn signal when he entered a turn-only lane, thus officers had no cause to stop Brown. The Washington Supreme Court disagreed, reversed the Court of Appeals, which upheld the trial court, and remanded for further proceedings.
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