State of Tennessee v. Brian Sherrill

The State appeals the trial court’s order granting the Defendant’s, Brian Sherrill, motion to suppress evidence seized as a result of a warrantless search of his vehicle. The Defendant argued that the arresting officer lacked probable cause or reasonable suspicion to believe that his truck’s brake light was malfunctioning. The State replied that the arresting officer had reasonable suspicion to stop the Defendant for either the brake light offense or an alleged seatbelt violation. The trial court addressed the brake light offense and concluded that the “totality of the circumstances” did not support the stop. After the trial court granted the Defendant’s suppression motion and dismissed the indictment, the State appealed. Following our review, we conclude that the trial court erred by not considering the State’s alternative theory attempting to establish that the stop was supported by reasonable suspicion of a seatbelt violation. Accordingly, we reverse the judgment of the trial court and remand the case for further proceedings.