Smith's Criminal Case Compendium
Smith's Criminal Case Compendium
Table of Contents
Smith's Criminal Case Compendium
About
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.
Instructions
Navigate using the table of contents to the left or by using the search box below. Use quotations for an exact phrase search. A search for multiple terms without quotations functions as an “or” search. Not sure where to start? The 5 minute video tutorial offers a guided tour of main features – Launch Tutorial (opens in new tab).
Arrest, Search, and Investigation > Arrests & Investigatory Stops > Stops > Reasonable Suspicion > Checkpoints
In this Harnett County case, the defendant pled guilty to impaired driving after the trial court denied her motion to suppress evidence obtained at a checking station set up to ensure compliance with Chapter 20 and to detect impaired driving. The Court of Appeals vacated the trial court’s order denying the motion to suppress, determining that the trial court did not adequately weigh the factors necessary to determine whether the public interest in the checking station outweighed its infringement on the defendant’s Fourth Amendment privacy interests. The State appealed. The Supreme Court reversed and reinstated the order of the trial court, finding that the unchallenged findings of fact supported the conclusion that the checking station was reasonable and constitutional as the relevant factors (gravity of public concern, degree to which seizure advances public interest, and severity of the interference with individual liberty) weighed in favor of the public interest. The Supreme Court cited the trial court’s findings that the checkpoint was carried out on a heavily traveled road pursuant to a plan that required the stopping of all vehicles during a time frame conducive to apprehending impaired drivers. The Court further relied upon the trial court’s findings that the checking station was operated under a supervising officer and that most drivers were stopped for less than one minute.
In this DWI case, the court held that a traffic checkpoint had a valid programmatic purpose and that G.S. 20-16.3A is constitutional. Troopers testified that the primary purpose of the checkpoint, which was conducted with prior approval from a supervisor, with an established plan, and without narcotics officers or drug dogs, was to check for driver’s licenses and evidence of impairment. The defendant’s primary challenge to the programmatic purpose of the checkpoint was that its location changed throughout the evening. Given that changing the location was planned prior to establishing the checkpoint and was authorized by the supervisor, the trial court properly determined that the checkpoint had a valid programmatic purpose. The court went on to hold G.S. 20-16.3A constitutional, specifically finding that the statute does not violate the right to free travel and does not impermissibly foreclose equal protection challenges arising from the placement of checkpoints.
In this impaired driving case, the trial court erred by denying the defendant’s motion to suppress, which had asserted that a checkpoint stop violated his constitutional rights. When considering a constitutional challenge to a checkpoint, a two-part inquiry applies: the court must first determine the primary programmatic purpose of the checkpoint; if a legitimate primary programmatic purpose is found the court must judge its reasonableness. The defendant did not raise an issue about whether the checkpoint had a proper purpose. The court noted when determining reasonableness, it must weigh the public’s interest in the checkpoint against the individual’s fourth amendment privacy interest. Applying the Brown v. Texas three-part test (gravity of the public concerns served by the seizure; the degree to which the seizure advances the public interest; and the severity of the interference with individual liberty) to this balancing inquiry, the court held that the trial court’s findings of fact did not permit the judge to meaningfully weigh the considerations required under the second and third prongs of the test. This constituted plain error.
Although the trial court properly found that the checkpoint had a legitimate proper purpose of checking for driver’s license and vehicle registration violations, the trial court failed to adequately determine the checkpoint’s reasonableness. The court held that the trial court’s “bare conclusion” on reasonableness was insufficient and vacated and remanded for appropriate findings as to reasonableness.
The trial court did not err by denying the defendant’s motion to suppress evidence obtained as a result of a vehicle checkpoint. The checkpoint was conducted for a legitimate primary purpose of checking all passing drivers for DWI violations and was reasonable.
In a DWI case, the court rejected the defendant’s argument that the checkpoint at issue was unconstitutional. The court first found that the checkpoint had a legitimate primary programmatic purpose, checking for potential driving violations. Next, it found that the checkpoint was reasonable.
The trial court did not err by granting the defendant’s motion to suppress evidence obtained as a result of a vehicle checkpoint. Specifically, the trial court did not err by concluding that a lack of a written policy in full force and effect at the time of the defendant’s stop at the checkpoint constituted a substantial violation of G.S. 20-16.3A (requiring a written policy providing guidelines for checkpoints). The court also rejected the State’s argument that a substantial violation of G.S. 20-16.3A could not support suppression; the State had argued that evidence only can be suppressed if there is a Constitutional violation or a substantial violation of Chapter 15A.
The trial court erred by granting the defendant's motion to suppress on grounds that a checkpoint was unlawful under G.S. 20-16.3A. Because the defendant did not actually stop at the checkpoint, its invalidity was irrelevant to whether an officer had sufficient reasonable suspicion to stop the defendant once he attempted to evade the checkpoint. The court vacated the order granting the motion to suppress and remanded.
The trial court did not err by concluding that the vehicle checkpoint passed constitutional muster. The trial court properly concluded that the primary programmatic purpose of the checkpoint was “the detection of drivers operating a motor vehicle while impaired and that the ‘procedure was not merely to further general crime control’” and that this primary programmatic purpose was constitutionally permissible. Applying the three-pronged test of Brown v. Texas, 443 U.S. 47, 50 (1979), the trial court properly determined that the checkpoint was reasonable.
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.
Declining to consider the defendant’s challenge to the constitutionality of a vehicle checkpoint where officers did not stop the defendant’s vehicle as a part of the checkpoint but rather approached it after the defendant parked it on the street about 100-200 feet from the checkpoint.