Commonwealth v. Eaves

In Commonwealth v. Eaves, 13 Va. App. 162, 408 S.E.2d 925 (1991), the officer observed the defendant make a U-turn approximately 100 feet to 1/10 mile before the traffic checkpoint. The officer testified that the defendant was traveling in the left southbound lane when "all of a sudden" he engaged his turn signal at a deceleration lane, made a U-turn, and headed back in the opposite direction from the roadblock. See Eaves, 13 Va. App. at 165, 408 S.E.2d at 927. The deceleration lane was only about 35-40 feet long. The officer described the turn of the vehicle as "abrupt," "immediate," and "quick." Id. The Court concluded that the officer's observations gave him a reasonable, articulable suspicion to stop the defendant. See id. at 166, 408 S.E.2d at 927-28.