State v. Matthews: Re-defining the Weight of Officer Testimony versus Dash-Cam Evidence in Particularized Suspicion Analysis

Introduction

State v. T. Matthews, 2025 MT 129, presented the Montana Supreme Court with a recurring yet increasingly modern problem: how should reviewing courts weigh live, contemporaneous video evidence against the sworn testimony and expertise of a trained law-enforcement officer when deciding whether “particularized suspicion” justified a traffic stop? Tyler Brandon Matthews was stopped for suspected impaired driving after Corporal Bethany Richter—an officer certified as a Drug Recognition Expert (DRE)— observed what she characterized as weaving within the lane, inconsistent speeds, and a slow, “wide” turn late at night near several bars.

Matthews moved to suppress all evidence flowing from the stop, arguing that the dash-cam footage disproved the officer’s narrative. Both the Yellowstone County Justice Court and the Thirteenth Judicial District Court sided with the State. On appeal, the Supreme Court was asked to decide whether the officer’s observations, juxtaposed with the video, amounted to the reasonable, particularized suspicion required by § 46-5-401(1), MCA. The Court affirmed the lower courts’ rulings (with one clerical correction), while a vigorous dissent warned that the decision dilutes constitutional protections by over-valuing subjective testimony.

Summary of the Judgment

Majority Holding. The Justice Court did not clearly err in finding that Corporal Richter possessed particularized suspicion to stop Matthews; therefore, the motion to suppress was properly denied.
Standard of Review Re-affirmed. On appeal from a justice court, the Supreme Court reviews the record as though the case came directly to it, assessing factual findings for clear error and legal conclusions for correctness.
Video Not Dispositive. Even where dash-cam footage exists, the trial factfinder may credit an officer’s on-scene observations and specialized training when video evidence is susceptible to differing reasonable interpretations.
Clerical Error Corrected. The written judgment’s $2,000 fine is amended to match the $600 fine orally pronounced at sentencing, under the principle articulated in State v. Lane.

Analysis

Precedents Cited and Their Influence

The Court’s opinion weaves several prior cases into its reasoning:

State v. McMaster, 2008 MT 294. Re-affirmed that particularized suspicion is evaluated under the “totality of the circumstances” test.
State v. Flynn, 2011 MT 48 & Weer v. State, 2010 MT 232. Both cases articulated the two-part requirement: (1) objective, articulable facts, and (2) reasonable inferences leading to suspicion of wrongdoing.
City of Missoula v. Sharp, 2015 MT 289. Provided the clear-error standard for factual findings on particularized suspicion.
State v. Reeves, 2019 MT 151, and State v. Fisher, 2002 MT 335 (cited in dissent). These cases limited stops based on minor, lawful driving behaviors—used by the dissent to argue that Matthews’ conduct fell short of suspicious behavior.
State v. Lane, 1998 MT 76. Cited for the rule that the oral pronouncement of sentence controls over a conflicting written judgment.

Legal Reasoning of the Majority

Justice McKinnon, writing for the Court, centered her reasoning on three pillars:

Deference to Fact-Finder Credibility Assessments. Trial courts see witnesses live and are best positioned to weigh demeanor and expertise—particularly where evidence (here, a dash-cam video) is “subject to differing reasonable interpretations.” The Court therefore would overturn only if the factual findings were “clearly erroneous.”
Totality of Circumstances. Richter’s observations (slow, wide turn; repeated weaving; inconsistent speed; late hour; proximity to bars), combined with her DRE credentials, collectively created the requisite suspicion, even if each fact in isolation might be innocent.
Video Ambiguity. The majority watched the dash-cam footage and acknowledged it could be read both ways—bolstering the notion that video alone does not necessarily defeat an officer’s in-person interpretation.

Potential Impact on Future Litigation

Enhanced Officer Testimony Weight. When qualified officers testify to impaired-driving cues, Montana courts are likely to defer, unless video footage irrefutably contradicts them. Defense counsel will need more than video “open to interpretation.”
Dash-Cam Evidence Not Automatically Controlling. The decision tempers the modern trend of treating video as the objective arbiter, signaling that trial courts retain discretion in reconciling conflicting evidence.
Clarification of Appellate Review. The Court reinforces that it acts as a direct reviewer of justice-court records, emphasizing clear-error deference.
Sentencing Housekeeping. By once again correcting a clerical error (Lane), the Court reminds practitioners to align written judgments with oral sentences—failure to do so will prompt remand but not reversal.
Split Decision Provides Ammunition for Both Sides. The dissent gives future appellants a roadmap: focus on cases where video clearly disproves testimony, and marshal precedent like Reeves and Fisher to argue that minor, lawful driving behaviors do not equal suspicion.

Complex Concepts Simplified

Particularized Suspicion: A level of suspicion less than probable cause but more than a vague hunch. It requires specific, articulable facts that create a reasonable inference the person is, was, or is about to be involved in wrongdoing.
Totality of the Circumstances: Courts look at all surrounding facts together, not each fact in isolation, to decide whether suspicion is reasonable.
Clear Error Standard: An appellate court will overturn a trial court’s factual finding only if it lacks substantial evidence, the court misapprehended the effect of evidence, or a firm conviction exists that a mistake has been made.
Drug Recognition Expert (DRE): An officer with advanced training in recognizing signs of drug or alcohol impairment. Their opinions carry added weight in assessing driving behavior.
Clerical Error in Judgments: A discrepancy between what the judge said in court (the oral sentence) and what is typed into the written judgment. Under State v. Lane, the oral sentence controls.

Conclusion

State v. Matthews significantly shapes Montana’s impaired-driving jurisprudence by confirming that trained officer testimony— even when partially contested by dash-cam video—can constitute the objective data necessary for particularized suspicion. The judgment underscores the deference appellate courts owe to trial courts’ credibility determinations, clarifies the procedural posture for justice-court appeals, and reiterates the supremacy of oral pronouncements in sentencing. While the dissent raises legitimate concerns about constitutional guardrails, the new precedent tilts the balance toward law-enforcement expertise in ambiguous situations. Future litigants must now recognize that video evidence, though powerful, is not dispositive unless it clearly and unequivocally contradicts officer observations.