Traffic Violations You May Not Even Know You Are Committing

Law enforcement officers may stop a vehicle when they have reasonable suspicion to believe that the driver has violated a traffic law. See State v. Styles, 362 N.C. 412, 415, 665 S.E.2d 438, 440 (2008). This rule applies regardless of whether the offense is a felony, misdemeanor or infraction, and regardless of whether the officer has an ulterior motive for making the stop. See Whren v. United States, 517 U.S. 806 (1996). The expansive scope of this authority is well-recognized.  Some have argued that the “heavy and minute[]” regulation of vehicles renders “total compliance with traffic and safety rules nearly impossible.” Whren, 517 U.S. at 810 (citing petitioner’s argument to this effect). Thus, they say, “a police officer will almost invariably be able to catch any given motorist in a technical violation.”  Id. A quick review of criminal case law provides some support for that notion. Law enforcement officers frequently substantiate more serious criminal conduct through citizen encounters that begin with a simple traffic stop.  See, e.g., State v. Heien, 366 N.C. 271 (2012) (defendant stopped for ostensible brake light violation and arrested for drug trafficking); State v. Dickenson, __ N.C. App. ___ (April 15, 2014) (unpublished) (defendant stopped for failure to wear seatbelt and arrested for drug trafficking); State v. Franklin, __ N.C. App. __, 736 S.E.2d 218 (2012) (defendant stopped for seatbelt violation and arrested for drug crimes); State v. Townes, ___ N.C. App. ___, 734 S.E.2d 139 (November 6, 2012) (unpublished) (defendant stopped based on DMV insurance stop [...]