Charales v. the State
329 Ga. App. 533
Ga. Ct. App.2014Background
- Charales was stopped at an Atlanta Police Department checkpoint and charged with DUI less safe and DUI per se after failing field sobriety tests and providing blood alcohol readings of .206 and .215.
- Charales filed a pretrial motion to suppress arguing the checkpoint was unlawful and the implied consent notice was not timely read; the trial court denied the motion.
- A stipulated bench trial resulted in Charales’s conviction on both counts, with the less safe count merged into the per se count.
- The trial court denied Charales’s motion for a new trial, and the Court of Appeals granted relief by reversing the denial of the suppression motion.
- The appellate court held the State failed to prove the APD checkpoint program had an appropriate primary purpose beyond ordinary crime control, invalidating the stop under the Fourth Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the APD checkpoint lawful under LaFontaine and Edmond? | Charales argues the checkpoint lacked a programmatic primary purpose. | State contends the checkpoint complied with LaFontaine and Edmond and was properly limited in scope. | Yes; the checkpoint violated the Fourth Amendment; conviction reversed. |
Key Cases Cited
- Brown v. State, 293 Ga. 787, 803 (3) (b) (2) (750 SE2d 148) (2013) (Ga. 2013) (establishes five requirements for checkpoint legality and Edmond analysis)
- Edmond v. City of Indianapolis, 531 U.S. 32 (U.S. 2000) (requires programmatic purpose focus for checkpoints)
- LaFontaine v. State, 269 Ga. 251 (497 SE2d 367) (1998) (Ga. 1998) (sets five-factor framework for checkpoint validation)
- Williams v. State, 293 Ga. 883 (2013) (Ga. 2013) (clarifies Edmond mechanics in Georgia context)