Missouri Court of Appeals, Western District / Nov 19, 2024
Amelia Briane Van Vickle vs. Director of Revenue
Amelia Van Vickle's driving license was administratively suspended after she was involved in a single-car accident and showed signs of intoxication. The circuit court set aside the suspension, finding she was not under arrest because she was not physically restrained. The Director of Revenue appealed. The appellate court reversed, holding that an injured and immobilized driver in an ambulance is considered "actually restrained" for the purpose of an arrest under Section 544.180, making further physical restraint by an officer unnecessary.