Appeal from the District Court, Fourth Judicial District, Fairbanks, Raymond M. Funk, Judge. Court of Appeals No. A-10433 Trial Court No. 4FA-07-2939 Cr
The opinion of the court was delivered by: Mannheimer, Judge.
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Before: Coats, Chief Judge, and Mannheimer and Bolger, Judges.
Steven L. Chase was driving in Fairbanks when a state trooper pulled him over because Chase was not wearing his seatbelt. During this traffic stop, the officer discovered that Chase should not have been driving at all; Chase's driver's license was canceled. Chase was subsequently convicted of driving with a canceled driver's license and driving without his seatbelt fastened. *fn1 He appeals his convictions, arguing three different theories as to why his convictions are unlawful.
Chase first argues that Alaska's seatbelt law is unconstitutional because it is an unjustified infringement of the rights of personal autonomy and liberty guaranteed by Article I, Section 1 of the Alaska Constitution.
Chase next argues that, even if Alaska's seatbelt law is constitutional as a general matter, the police officer in Chase's case engaged in an unreasonable seizure (that is, a seizure in violation of the Fourth Amendment to the federal Constitution and Article I, Section 14 of the Alaska Constitution) when the officer pulled Chase over to give him a citation for failing to wear his seatbelt.
Chase acknowledges that, under AS 12.25.030(a) and AS 12.25.180(b), police officers have the authority to arrest or issue a citation to any person who commits an offense in their presence. Chase nevertheless argues that this authority to arrest or to cite must be exercised "reasonably", because the Constitution forbids unreasonable seizures.
According to Chase, even when a police officer has probable cause to believe that an individual has violated the law, the search-and-seizure provisions of the federal and state constitutions require courts to determine, on a case-by-case basis, whether the police seizure of that individual was "reasonable" -- by weighing (1) the government's interest in enforcing that particular law against (2) the individual's interest in liberty and privacy. With regard to his particular case, Chase contends that the police officer's decision to stop him was unreasonable because the government had only a negligible interest in enforcing the seatbelt law, while Chase had a significant personal interest in not being detained by the police.
Finally, Chase argues that even if the seatbelt statute is constitutional as a general matter, and even if the traffic stop of Chase's vehicle was reasonable for purposes of the search-and-seizure clause, the police officer's act of stopping Chase was a "pretext" stop, and thus all evidence obtained during that stop must be suppressed.
For the reasons explained here, we conclude that none of Chase's claims has merit, and we therefore affirm his convictions.
Whether Alaska's seatbelt law infringes the rights of personal liberty, autonomy, and privacy guaranteed by the Alaska Constitution
We first address Chase's argument that the seatbelt law is unconstitutional as a general matter. Chase contends that whatever governmental interest there may be in having people wear seatbelts is outweighed by the rights of personal liberty and autonomy guaranteed by Article I, Section 1 of the Alaska Constitution.
Article I, Section 1 of our state constitution declares that "all persons have a natural right to life, liberty, the pursuit of happiness, and the enjoyment of the rewards of their own industry". In Breese v. Smith, 501 P.2d 159, 168-172 (Alaska 1972), the Alaska Supreme Court interpreted this provision as guaranteeing a certain level of personal autonomy, and as creating a sphere of ...