State v. Eagle: Blue Lights and Impeded Egress Equal a Fourth Amendment Seizure

The North Carolina Court of Appeals in State v. Eagle, 2022-NCCOA-680, ___ N.C. App. ___, 879 S.E.2d 377 (2022), considered whether the driver of a car that had already stopped when a patrol officer pulled in behind it with blue lights activated was seized within the meaning of the Fourth Amendment. The trial court had ruled that the driver was not immediately seized by the officer in this encounter. Instead, the court ruled that a seizure occurred only when the officer took Ms. Eagle’s driver’s license and returned to her patrol car. By this point, the officer had developed reasonable suspicion to believe Ms. Eagle was impaired. The Court of Appeals reversed, determining that Eagle was seized at the outset of this encounter. This post discusses State v. Eagle and its relationship to other recent seizure jurisprudence. Facts. An Orange County Sheriff’s deputy was performing nightly business checks at Maple View Farms around 3 a.m. when she saw the defendant’s car pull into the driveway of the Maple View Agricultural Center, which was closed. The entrance drive was blocked by a locked gate. The deputy pulled into the driveway behind the car with her blue lights on.  She stopped at an angle about 10 feet behind the car, blocking it into the driveway. The deputy testified that she turned on her blue lights not because she had seen a criminal violation but instead for safety reasons since her patrol car was jutting out into the road when she stopped. The deputy [...]