Combs v. Robertson, 239 N.C. App. 135 (Feb. 3, 2015)

The Fourth Amendment’s exclusionary rule does not apply in civil drivers’ license revocation proceedings. The evidence used in the proceeding was obtained as a result of an unconstitutional stop; after the same evidence previously had been used to support criminal charges, it was suppressed and the criminal charges were dismissed. The court held that while the evidence was subject to the exclusionary rule in a criminal proceeding, that rule did not apply in this civil proceeding, even if it could be viewed as “quasi-criminal in nature.”