State v. Wilkes, ___ N.C. App. ___, 807 S.E.2d 672 (Nov. 7, 2017)

In this murder case, officers had probable cause to arrest the defendant. Thus, the trial court did not err by denying the defendant’s motion to suppress incriminating statements made by the defendant after arrest. After law enforcement discovered a woman’s body inside an abandoned, burned car, officers arrested the defendant. During question after arrest, the defendant implicated himself in the woman’s murder. He unsuccessfully moved to suppress those incriminating statements and challenged the trial court’s denial of his suppression motion on appeal. At the time the officers arrested the defendant, they had already visited the victim’s home and found a knife on the chair near a window with the cut screen. When they questioned the victim’s boyfriend, he admitted that he was with the defendant at the victim’s home on the night of the murder and that, after the victim locked the two men out of her house, the boyfriend cut the screen, entered the house through the window, unlocked the door from the inside, and let the defendant in. These facts and circumstances constituted sufficient, reasonably trustworthy information from which a reasonable officer could believe that the defendant had committed a breaking and entering. Thus, regardless of whether the officers had probable cause to arrest the defendant for murder, they had probable cause to arrest the defendant for that lesser crime.