State v. Jarrett, 203 N.C. App. 675 (May. 4, 2010)

The vehicle checkpoint did not violate the defendant’s Fourth Amendment rights. The primary programmatic purpose of the checkpoint—to determine if drivers were complying with drivers license laws and to deter citizens from violating these laws—was a lawful one. Additionally, the checkpoint itself was reasonable, based on the gravity of the public concerns served by the seizure, the degree to which the seizure advanced the public interest, and the severity of the interference with individual liberty. The court also held that the officer had reasonable, articulable suspicion to continue to detain the 18-year-old defendant after he produced a valid license and registration and thus satisfied the primary purpose of the vehicle checkpoint. Specifically, when the officer approached the car, he saw an aluminum can between the driver’s and passenger’s seat, and the passenger was attempting to conceal the can. When the officer asked what was in the can, the defendant raised it, revealing a beer can.