Jorge Rangel, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2025)

MEMORANDUM DECISION

Statement of the Case

[1] Jorge Rangel was stopped by Indiana State Police Trooper Luis Alvarez for failing to signal his exit off a highway in Elkhart, Indiana. At his bench trial, the trial court admitted, over Rangel's objection, evidence discovered pursuant to the stop. Rangel now appeals and raises one issue for our review: Whether the trial court abused its discretion by admitting certain evidence at trial.

[2] We affirm.

Facts and Procedural History

[3] On February 3, 2024, Trooper Alvarez was parked on the I-80 Toll Road in Elkhart County, Indiana, “running radar” when he observed Rangel “traveling about 50 miles per hour in a 70 miles per hour zone.” Tr. Vol. II at 38. Rangel's slow speed caught Trooper Alvarez's attention, so after Rangel passed Trooper Alvarez and exited the highway without signaling, Trooper Alvarez conducted a traffic stop. Based on Rangel's driving, demeanor, and odor of consumed alcohol, Trooper Alvarez believed Rangel to be intoxicated. Rangel later consented to a certified breath test, which reflected a concentration of 0.175 grams of alcohol per 210 liters of breath.

[4] Rangel was charged with operating a vehicle while intoxicated endangering a person as a Class A misdemeanor (the “Endangering Count”)  ¹ and operating a vehicle with an alcohol concentration equivalent to .15 or more as a Class A misdemeanor (the “ACE Count”)² . On June 19, Rangel filed a motion to “suppress all evidence gleaned” from the stop, arguing the stop was unlawful. Appellant's App. Vol. II at 37. The trial court denied Rangel's motion to suppress. During the ensuing bench trial, Rangel renewed his objection to the admission of the evidence. The trial court overruled the objection and later convicted Rangel on the ACE Count and sentenced him to 365 days, all suspended. This appeal ensued.  ³

Discussion and Decision

The Trial Court Did Not Abuse Its Discretion by Admitting Certain Evidence

[5] Rangel contends the trial court erred in admitting certain evidence at trial. We generally review rulings on admissibility of evidence for an abuse of discretion. Russell v. State, 234 N.E.3d 829, 858 (Ind. 2024) (quoting Conley v. State, 972 N.E.2d 864 (Ind. 2012)), cert. denied, 145 S.Ct. 424 (2024). “When, however, admissibility turns on questions of constitutionality relating to the search and seizure of that evidence, our review is de novo.” Jacobs v. State, 76 N.E.3d 846, 849 (Ind. 2017) (citing Guilmette v. State, 14 N.E.3d 38, 40 (Ind. 2014)).

[6] Rangel specifically argues that Trooper Alvarez lacked the authority to stop him under both the Fourth Amendment to the United States Constitution and Article 1, Section 11 of the Indiana Constitution, so the trial court erred by overruling Rangel's objection to the admission of evidence stemming from the stop. We begin with Rangel's Fourth Amendment argument, which he identified at oral argument as his primary claim.⁴

[7] The Fourth Amendment proscribes “unreasonable searches and seizures,” U.S. Const. amend. IV, and “[a] traffic stop is a ‘seizure’ subject to the constraints imposed by” the Fourth Amendment, Campos v. State, 885 N.E.2d 590, 597 (Ind. 2008). The purpose of the Fourth Amendment “is to safeguard the privacy and security of individuals against arbitrary invasions by governmental officials.” Carpenter v. United States, 585 U.S. 296, 303 (2018) (quoting Camara v. Mun. Ct. of City & Cnty. of San Francisco, 387 U.S. 523, 528 (1967)).

[8] Rangel's appellate arguments focus almost exclusively on statutory interpretation of Indiana Code section 9-21-8-24(a)(2) and whether his exit from the highway constituted a turn. In relevant part, Indiana Code section 9-21-8- 24(a)(2) provides that a person must signal before “turn[ing] a vehicle from a direct course upon a highway.” Rangel argues that “turn” requires “significant rotation” of a vehicle's wheels or axle, and his exit from the highway was “non-rotational.” Appellant's Br. at 13. Rangel contends Trooper Alvarez made a mistake of law in stopping him because a signal was not required. Therefore, Trooper Alvarez lacked authority to stop Rangel and all evidence discovered pursuant to the stop “must be suppressed.” Id. at 10. In so arguing, Rangel fails to acknowledge that (1) “reasonableness” is “the ultimate touchstone of the Fourth Amendment,” Heien v. North Carolina, 574 U.S. 54, 60 (2014) (quoting Riley v. California, 573 U.S. 373, 381 (2014)); and (2) an objectively reasonable mistake of law does not invalidate a traffic stop, id. at 66.

[9] The State likewise devotes much of its argument to statutory interpretation. The State argues that Rangel's exit off the highway was a turn “from his direct course upon the highway” because Rangel rotated his wheel enough to leave his direction of travel on the highway to enter the exit ramp, and Rangel was therefore required to signal. Appellee's Br. at 10. We decline to choose between the parties’ differing statutory interpretations of Indiana Code Section 9-21-8-24 and consider instead whether the mistake of law—assuming there was one—was reasonable.

[10] In Heien v. North Carolina, a law enforcement officer pulled over a driver because he only had one brake light working, and the driver was later charged with attempted trafficking of cocaine following a search of the vehicle. 574 U.S. at 58. A North Carolina appellate court later interpreted the applicable statute and determined that it only required a single brake light. Id. at 59 (citing N.C. Gen. Stat. Ann. § 20–129(g) (2007)). Nevertheless, the United States Supreme Court held that even though the officer was mistaken about what the law required, his mistake of law was reasonable under the circumstances given the apparent ambiguity in the language of the statute. Id. at 67–68.

[11] Here, we conclude without difficulty that Trooper Alvarez's mistake of law, if indeed he made one, was reasonable. Drivers are required to signal before “turn[ing] a vehicle from a direct course upon a highway.” Ind. Code § 9-21-8-24(a)(2). The parties put forth reasonable and conflicting interpretations of this section using the benefit of time and research—something Trooper Alvarez lacked when making an on-the-spot determination. “Where, as here, multiple meanings of a particular word or phrase in a statute are possible, when reviewing police action, the question must be whether the officer's on-the-spot determination was reasonable.” Lanier v. State, -- N.E.3d --, 2025 WL 3058889, at *5 (Ind. Ct. App. 2025). Because Trooper Alvarez could have reasonably believed that Rangel turned his “vehicle from a direct course upon a highway,” I.C. § 9-21-8-24(a)(2), any mistake of law, if it occurred, was reasonable, see Heien, 574 U.S. at 68. The traffic stop, therefore, did not violate the Fourth Amendment, and the trial court did not abuse its discretion by admitting the evidence discovered therefrom.⁵

[12] Affirmed.

FOOTNOTES

1.   Ind. Code § 9-30-5-2(b).

2.   I.C. § 9-30-5-1(b)(2).

3.   On December 8, 2025, we held oral argument at Muncie Central High School in Muncie, Indiana. We thank the faculty and staff of the school for their hospitality and all counsel for the quality of their advocacy. We also thank the students in attendance from Muncie Central High School, Burris Laboratory School, and Wapahani High School who respectfully observed the oral argument.

4.   Oral Argument at 04:17–04:21, Rangel v. State, No. 25A-CR-1134 (Ind. Ct. App. Dec. 8, 2025), https://mycourts.in.gov/arguments/default.aspx?&id=3061&view=detail&yr=&when=&page=1&court=&s earch=&direction=%20ASC&future=False&sort=&judge=&county=&admin=False&pageSize=20.

5.   Rangel makes a passing reference to Article 1, Section 11 of the Indiana Constitution in his brief but fails to provide an independent analysis thereunder. Rangel has therefore waived his Article 1, Section 11 claim. See Ind. Appellate Rule 46(A)(8)(a) (requiring cogent reasoning); Miller v. Patel, 212 N.E.3d 639, 657 (Ind. 2023). Waiver notwithstanding and assuming without deciding a mistake of law occurred, we agree with the Lanier panel that a reasonable mistake of law passes Indiana constitutional muster; thus, Trooper Alvarez's actions were reasonable and did not violate Rangel's rights under Article 1, Section 11. See Lanier v. State, -- N.E.3d - -, 2025 WL 3058889, at *6 (Ind. Ct. App. 2025).

Felix, Judge.

Weissmann, J., and Kenworthy, J., concur.