Beverly S. Jackson Muscatell, Petitioner Below, Appellee v. Jane L. Cline

Summary

The court reversed the circuit court’s order overturning the DMV’s six-month revocation of Muscatell’s driver’s license and remanded for the Commissioner to determine whether the investigatory stop was lawful under the reasonable-suspicion standard. It held that HGN evidence may be considered as evidence that a driver was under the influence, subject to established limitations, but concluded that the agency had not adequately resolved conflicting testimony about the basis for the stop. Justice Workman, dissenting, would have upheld the stop under an objective-reasonableness analysis without remand.