Smith's Criminal Case Compendium

This compendium includes significant criminal cases by the U.S. Supreme Court & N.C. appellate courts, Nov. 2008 – Present. Selected 4th Circuit cases also are included.

Jessica Smith prepared case summaries Nov. 2008-June 4, 2019; later summaries are prepared by other School staff.

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Arrest, Search, and Investigation > Arrests & Investigatory Stops > Stops > Reasonable Suspicion > Community Caretaking Justification

State v. Huddy, ___ N.C. App. ___, 799 S.E.2d 650 (Apr. 18, 2017)

Arrest, Search, and Investigation > Searches > Community Caretaking, as Justification for Warrantless Search

Because an officer violated the defendant’s fourth amendment rights by searching the curtilage of his home without a warrant, the trial court erred by denying the defendant’s motion to suppress. The officer saw a vehicle with its doors open at the back of a 150-yard driveway leading to the defendant’s home. Concerned that the vehicle might be part of a break-in or home invasion, the officer drove down the driveway, ran the vehicle’s tags, checked—but did not knock—on the front door, checked the windows and doors of the home for signs of forced entry, “cleared” the sides of the house, and then went through a closed gate in a chain-link fence enclosing the home’s backyard and approached the storm door at the back of the house. As the officer approached the door, which was not visible from the street, he smelled marijuana, which led to the defendant’s arrest for drug charges. At the suppression hearing, the State relied on two exceptions to the warrant requirement to justify the officer’s search of the curtilage: the knock and talk doctrine and the community caretaker doctrine. The court found however that neither exception applies. First, the officer did more than nearly knock and talk. Specifically, he ran a license plate not visible from the street, walked around the house examining windows and searching for signs of a break-in, and went first to the front door without knocking and then to a rear door not visible from the street and located behind a closed gate. “These actions went beyond what the U.S. Supreme Court has held are the permissible actions during a knock and talk.” Likewise, the community caretaker doctrine does not support the officer’s action. “The presence of a vehicle in one’s driveway with its doors open is not the sort of emergency that justifies the community caretaker exception.” The court also noted that because the fourth amendment’s protections “are at their very strongest within one’s home,” the public need justifying the community caretaker exception “must be particularly strong to justify a warrantless search of a home.”

State v. Sawyers, ___ N.C. App. ___, 786 S.E.2d 753 (June 7, 2016)

Arrest, Search, and Investigation > Arrests & Investigatory Stops > Stops > Reasonable Suspicion > Miscellaneous Cases

(1) A stop of the defendant’s vehicle was justified by reasonable suspicion. While on patrol in the early morning, the officer saw the defendant walking down the street. Directly behind him was another male, who appeared to be dragging a drugged or intoxicated female. The defendant and the other male placed the female in the defendant’s vehicle. The two then entered the vehicle and left the scene. The officer was unsure whether the female was being kidnapped or was in danger. Given these circumstances, the officer had reasonable suspicion that the defendant was involved in criminal activity. (2) Additionally, and for reasons discussed in the opinion, the court held that the stop was justified under the community caretaking exception.

State v. Smathers, 232 N.C. App. 120 (Jan. 21, 2014)

In a case where the State conceded that the officer had neither probable cause nor reasonable suspicion to seize the defendant, the court decided an issue of first impression and held that the officer’s seizure of the defendant was justified by the “community caretaking” doctrine. The officer stopped the defendant to see if she and her vehicle were “okay” after he saw her hit an animal on a roadway. Her driving did not give rise to any suspicion of impairment. During the stop the officer determined the defendant was impaired and she was arrested for DWI. The court noted that in adopting the community caretaking exception, “we must apply a test that strikes a proper balance between the public’s interest in having officers help citizens when needed and the individual’s interest in being free from unreasonable governmental intrusion.” It went on adopt the following test for application of the doctrine:

[T]he State has the burden of proving that: (1) a search or seizure within the meaning of the Fourth Amendment has occurred; (2) if so, that under the totality of the circumstances an objectively reasonable basis for a community caretaking function is shown; and (3) if so, that the public need or interest outweighs the intrusion upon the privacy of the individual.

After further fleshing out the test, the court applied it and found that the stop at issue fell within the community caretaking exception.

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