Armentrout v. the State
332 Ga. App. 370
Ga. Ct. App.2015Background
- Armentrout was stopped at a Johns Creek traffic checkpoint during a July 4, 2011 operation aimed at traffic safety and DUI detection.
- She was educated through an alco-sensor test, field sobriety tests, and subsequently arrested for DUI less safe and DUI per se after a positive BAC reading.
- The State charged two DUI offenses and Armentrout moved to suppress the stop evidence and the BAC test results due to an unlawful checkpoint and allegedly misleading re-reading of the implied-consent warning.
- A combined evidentiary hearing occurred and the trial court denied both suppression motions, leading to a stipulated bench trial and convictions on both counts.
- The appellate review proceeded under de novo review for the law applied to undisputed facts, with disputed-fact findings given deferential treatment.
- The court reversed, holding the checkpoint program lacked a proven primary purpose beyond ordinary crime control, rendering the stop unconstitutional.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the checkpoint program had a lawful primary purpose | Armentrout; checkpoint program lacked appropriate primary purpose beyond crime control. | State; the checkpoint had a lawful purpose and complied with LaFontaine and Edmond under programmatic analysis. | Checkpoint program lacked required primary purpose; suppression affirmed |
Key Cases Cited
- LaFontaine v. State, 269 Ga. 251 (Ga. 1998) (roadblock prerequisites include supervisory decision, uniform stops, minimal delay, identifiable checkpoint, trained screening officer)
- City of Indianapolis v. Edmond, 531 U.S. 32 (U.S. 2000) (checkpoint program must have a primary purpose beyond general crime control)
- Williams v. State, 293 Ga. 883 (Ga. 2013) (requires program-level showing of proper primary purpose; supports Edmond analysis)
- Brown v. State, 293 Ga. 787 (Ga. 2013) (further development of Edmond requirements for checkpoint programs)
- Conner v. State, 322 Ga. App. 636 (Ga. App. 2013) (deference to trial court on disputed facts; use in laws-of-evidence context)