State v. Jones, ___ N.C. App. ___, 813 S.E.2d 668 (Apr. 3, 2018)

At a suppression hearing, the trial court may consider testimony from an officer about a vehicle stop that includes material information not contained in the officer’s contemporaneous reports. On the date of the traffic stop, Trooper Myers—the stopping officer--made handwritten notes in an Affidavit and Revocation Report and in a Driving While Impaired Report form (DWIR form). He testified that for most of his impaired driving cases, he was unable to put a lot of information on the DWIR form due to space constraints and his own sloppy handwriting. His practice was to later type his full observations into a Word document so that it would be easier to read. He followed this practice with respect to the incident in question, typing his notes into a Word document the following day; these notes contained greater detail about the incident than the prior Revocation Report or DWIR form. The court rejected the defendant’s argument that the trial court could not consider additional details included in the typed notes. This additional information supplemented rather than contradicted that in the earlier-created documents.