Resurrecting the Good Faith Exception in North Carolina?

Conventional wisdom says that unlike the federal court system, we do not have a good faith exception under North Carolina law. Even though G.S. 15A-974 was amended in 2011 and now expressly provides for a statutory good faith exception, most practitioners agree that its use remains off limits under our state constitution unless and until State v. Carter is overruled. If you had asked me a month ago, I would have confidently said "yep, that's the law." Today, I'm a little less sure. Two recent Court of Appeals decisions have renewed the question of whether Carter actually says what we think it does. Quick History Lesson: Bob Farb covered this topic in his first-ever blog post nearly ten years ago, so I will try not to duplicate all of his work here, but a brief recap may be helpful. 1. Good Faith vs. Carter: The good faith exception says that evidence obtained in violation of the defendant's Fourth Amendment rights may nevertheless be admissible if the officer was acting in objectively reasonable reliance on a search warrant or other legal authority, even if that basis is later found to be invalid. See United States v. Leon, 468 U.S. 897 (1984); Massachusetts v. Sheppard, 468 U.S. 981 (1984); Herring v. United States, 555 U.S. 135 (2009); Davis v. United States, 564 U.S. 229 (2011). The exclusionary rule is premised on deterring intentionally unlawful conduct by the police, but the courts have recognized that achieving deterrence by excluding relevant evidence is a "bitter [...]