People v. Chaffee

In People v. Chaffee (183 A.D.2d 208 [1992]) the Court permitted the stop of a vehicle by a Trooper who was involved in a sobriety checkpoint. The vehicle in that case "made a 'very quick stop' in the road and turned right into a motel parking lot. The Trooper followed that car into the lot and observed that it circled the lot two times, passing numerous parking spaces. The occupants were looking toward the roadblock. It was only after the Trooper activated his roof lights that the car pulled into a parking space." (Chaffee, supra at 209.) The result was that the driver of that vehicle was eventually arrested for felony driving while intoxicated. The articulable fact which permitted the investigatory stop was that the defendant "appeared to be avoiding the checkpoint." (Chaffee, supra at 211.) In People v. Chaffee, the State Police had established a "registration and sobriety" checkpoint. A trooper manning that checkpoint observed the defendant's vehicle turn into a motel parking lot rather than go through the roadblock. The trooper then observed the defendant's vehicle circle the lot twice and pull into a space as the trooper's car approached. The trooper approached the defendant's vehicle and, upon smelling alcohol on his breath, placed him under arrest. In upholding the arrest, the Court stated: "Where . . . the police have established a nonarbitrary uniform procedure to stop all motorists at the checkpoint or who reasonably appear to be avoiding the checkpoint, we should give deference to the enforcement procedures established by the police agency." (Id. at 211.)