State v. Carrouthers, 200 N.C. App. 415 (Oct. 20, 2009)

The trial court applied the wrong legal standard when granting the defendant’s motion to suppress. The trial court held that an arrest occurred when the defendant was handcuffed by an officer, and the arrest was not supported by probable cause. The trial court should have determined whether special circumstances existed that would have justified the officer’s use of handcuffs as the least intrusive means reasonable necessary to carry out the purpose of the investigative stop. The court remanded for the required determination.