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 investigatory stop based on her repeated lane drifting, near collision with a concrete island, and sharp corrective swerve. The Court declined to decide whether the community caretaker doctrine justified the stop because the stop was independently supported by the totality of the circumstances. Justice Valihura concurred only in the judgment, concluding that the stop was justified by the officer’s reasonable mistake that West violated the single-lane statute, not by pre-stop suspicion of DUI.