Tracey West, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The Court affirmed West’s DUI conviction, holding that the officer had reasonable and articulable suspicion to make an investigative stop based on West’s repeated drifting within her lane, near-collision with a concrete island, and sharp corrective turn. The Court found it unnecessary to decide whether the community caretaker doctrine authorized the stop because the stop was independently justified under the Fourth Amendment. Justice Valihura concurred only in the judgment, reasoning that the stop was justified by a reasonable mistake that West had violated the single-lane requirement and that DUI suspicion arose only after the stop.