State v. Creed

¶1 In State v. Snapp, 174 Wn.2d 177, 275 P.3d 289 (2012), the Washington Supreme Court held that a *537police officer’s Terry1 stop of a driver on a dark evening for failure to have his headlights illuminated was supported by a reasonable, articulable suspicion even though it was later demonstrated that the officer stopped the driver only 24 minutes after sunset, whereas the applicable statute, RCW 46.37.020, generally requires that headlights be illuminated beginning one-half hour after sunset. “[T]he question of a valid stop does not depend upon [a defendant’s] actually having violated the…