United States v. Goodwin (1981) – Case Brief Summary (Federal Court)

In United States v. Goodwin, 637 F.2d 250, 256 (4th Cir. 1981) rev'd on other grounds, 457 U.S. 368 (1982), in considering T.A. § 21-904, the Fourth Circuit Court of Appeals found that the purpose of the then existing 1970 version of the statute was to affect compliance with an officer's signal to stop.

The Court explained:

Not unreasonably, notice of the authority of the officer to give the signal is an essential element of the crime of failing to obey. That notice is given when the officer is on foot and is wearing his uniform and insignia of office, or, if the officer is in a vehicle, when the vehicle is marked as an official police vehicle. In the latter instance, additional notice from the wearing of a uniform and displaying an insignia of office is unnecessary, especially when it is remembered that the garb of the policeman within the official police vehicle may not even be visible.

A contrary reading would lead to some bizarre results. If both conditions must be alleged and proved in order to render § 21-904 applicable, a motorist with impunity could ignore a signal to stop from a plainclothes policeman in an official police car or an off-duty policeman in a official car. We do not think that these possibilities were intended by the Maryland legislature. Id.

In Goodwin, the defendant had been convicted of "Fleeing and Eluding" under T.A. § 21-904, which at that time required that an officer give a visual or audible signal to stop, in an appropriately marked police vehicle and that the officer be in uniform prominently displaying his badge or the insignia of office. 637 F.2d at 251, 255-56.

In Goodwin, although the indictment charged that the defendant had been given a signal to stop by an officer in a vehicle appropriately marked as a police vehicle, the indictment did not, however, allege that the officer was in uniform or displaying a badge. 637 F.2d at 256.

Against this background, the Fourth Circuit Court of Appeals found that "if both conditions of the statute must be alleged and proved to render T.A. § 21-904 applicable, a motorist could ignore a signal to stop from a plainclothes police officer in an official police car." Id.