State of Tennessee v. Guy Binette

Summary

The Tennessee Supreme Court held that when a trial court's findings of fact at a suppression hearing rest solely on evidence raising no credibility issues—here a dashboard videotape—the reviewing court must examine the record de novo without a presumption of correctness, carving this situation out of the deferential Odom standard. Applying that standard, the Court independently reviewed the videotape and found no pronounced weaving or hard swerving: Binette merely drifted occasionally within his lane while properly navigating intersections and maintaining following distances on a winding road, which did not give Officer Davis reasonable suspicion of driving under the influence. Because the stop violated the Fourth Amendment and Article I, section 7 of the Tennessee Constitution, the Court reversed the suppression denials of the trial court and Court of Criminal Appeals, vacated the conditional-guilty-plea conviction, and dismissed the DUI charge. Justice Holder dissented, contending the traditional Odom presumption-of-correctness standard should have governed and that the officer's admissible audio statements together with the trial court's 'fairly significant weaving' finding established reasonable suspicion.