State v. Cobb, 2022-NCSC-57, ___ N.C. ___ (May. 6, 2022)

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.