Supreme Court Reinstates DUI Charges in Case Where Suspect Passed Field Sobriety Tests

February 20, 2014

The Tennessee Supreme Court today reinstated DUI charges against David Dwayne Bell. Mr. Bell was stopped in 2009 by police for driving on the wrong side of a divided highway and performed several field sobriety tests with reasonable success.

Despite his performance on the tests, police arrested Mr. Bell for DUI because he smelled of alcohol, and he admitted that he had drunk “more than he should have.”

The Circuit Court for Sevier County suppressed blood alcohol test results and dismissed all charges, finding that police lacked probable cause to arrest Mr. Bell. In light of Mr. Bell’s satisfactory performance on the field sobriety tests, the Court of Criminal Appeals agreed.

In a unanimous opinion, the Supreme Court ruled that police had probable cause to arrest Mr. Bell for DUI. The Court observed that the existence of probable cause is quite distinct from guilt at trial. While a criminal conviction must be supported by proof beyond a reasonable doubt, probable cause requires only facts that would support a prudent person’s belief that the defendant committed an offense.

Mr. Bell’s significant driving error, odor of alcohol, and admission of drinking warranted a belief that he was driving under the influence and, therefore, established probable cause for his arrest. The Court, recognizing that an individual may pass field sobriety tests and still be under the influence of alcohol, concluded that Mr. Bell’s satisfactory performance on field sobriety tests did not sufficiently undermine the belief that he was driving under the influence.

Read the State of Tennessee v. David Dwayne Bell opinion, authored by Justice William C. Koch, Jr.