State v. Salinas, 366 N.C. 119 (Jun. 14, 2012)

The court modified and affirmed State v. Salinas, 214 N.C. App. 408 (Aug. 16, 2011) (trial court incorrectly applied a probable cause standard instead of a reasonable suspicion standard when determining whether a vehicle stop was unconstitutional). The supreme court agreed that the trial judge applied the wrong standard when evaluating the legality of the stop. The court further held that because the trial court did not resolve the issues of fact that arose during the suppression hearing, but rather simply restated the officers’ testimony, its order did not contain sufficient findings of fact to which the court could apply the reasonable suspicion standard. It thus remanded for the trial court to reconsider the evidence pursuant to the reasonable suspicion standard.