Michigan Court of Appeals: A Traffic Stop Based on Insurance Information in LEIN is Valid

Patrick Mazzie was a passenger in his friend’s car when the police conducted a traffic stop because the Law Enforcement Information Network (“LEIN”) said the car insurance on the vehicle was expired. The LEIN system is an information sharing network used by law enforcement and is accessible via the computers mounted in police cruisers. Following a search, Mazzie was charged with cocaine possession with intent to deliver and maintaining a drug house.

The trial court granted Mazzie’s motion to suppress finding that the traffic stop was unlawful. In deciding the motion, the trial court decided the insurance information provided to LEIN was not reasonably accurate or current enough to provide the police with reasonable suspicion for the traffic stop. The information in LEIN was updated only twice monthly. The trial court also found that providing the information to LEIN for the purpose of traffic stops violated confidentiality provisions of two statutes: MCL 257.227(4) and MCL 500.3101a(3). Because the trial court ruled the stop was unlawful, the evidence obtained as a result was suppressed.

On appeal, the Michigan Court of Appeals reversed the trial court’s order to suppress the evidence. The Michigan Court of Appeals made the following holdings: (1) the traffic stop to check for valid insurance was reasonable under the Fourth Amendment because the officer had a reasonable suspicion that the driver was driving without valid insurance in violation of MCL 500.3102 based on the information in LEIN; (2) even if providing insurance information to LEIN violated confidentiality provisions of MCL 257.227 and MCL 500.3101a, there is no statutory remedy provided under the exclusionary rule; and (3) the delayed reporting of insurance information only twice a month did not render an officer’s reliance on the information in making a stop unreasonable (testimony established the LEIN insurance information was accurate at least 90% of the time). Click the following link to read the decision: People v Mazzie.

Given the outcome of this case, it appears police can conduct a lawful traffic stop based on insurance information found in LEIN.

If you are charged with a crime following a traffic stop, please contact one of the experienced West Michigan criminal defense attorneys at Butler, Toweson & Payseno.