Smith's Criminal Case Compendium
Table of Contents
Evidence
Arrest, Search, and Investigation
Criminal Offenses
Drug Offenses
Hartman v. Robertson, 208 N.C. App. 692 (Dec. 21, 2010)
(1) In an appeal of a driver’s license revocation under G.S. 20-16.2(e), the court declined to consider the defendant’s argument that the officer lacked reasonable and articulable suspicion to stop his vehicle. Reasonable and articulable suspicion for the stop is not relevant to determinations in connection with a license revocation; the only inquiry with respect to the officer, the court explained, is that he or she have reasonable grounds to believe that the person has committed an implied consent offense. Here, the evidence supported that conclusion. (2) The exclusionary rule does not apply in a civil license revocation proceeding.