State v. Blankenship, 230 N.C. App. 113

Officers received a BOLO about a red Mustang with a black top (license XXT-9756) driving erratically on Patton Avenue.
Anonymous 911 tipster Hutchby reported the Mustang’s erratic driving and provided its license plate; he was not personally known to or interviewed by the officers.
Officer Jones detected a strong odor of alcohol from defendant and conducted field sobriety tests after stopping the vehicle at a school gate.
No traffic-law violations or observed impairment were initially seen; destination was to enter Asheville Private School property.
The officers lacked time to observe the vehicle’s operation prior to stopping and did not corroborate Hutchby’s tip; Hutchby’s tip did not establish reliable indicia.
Defendant pled guilty to DWI; on appeal, the denial of the suppression motion was challenged as improper warrantless stop.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was reasonable suspicion for a warrantless stop	Blankenship argues the anonymous tip lacked reliability	State argues tip had sufficient indicia of reliability or corroboration	Stop not supported by reasonable suspicion; suppression reversed

State v. Peele, 196 N.C. App. 668 (2009) (standard for reviewing suppression rulings; credibility not established)
State v. Hughes, 353 N.C. 200 (2000) (reasonable suspicion requires minimal objective justification)
State v. Washington, 193 N.C. App. 670 (2008) (anonymous tip can justify stop with indicia of reliability)
State v. McRae, 203 N.C. App. 319 (2010) (tip reliability assessed before stop; corroboration often needed)
State v. Hudgins, 195 N.C. App. 430 (2009) (face-to-face tip reliability and credibility evaluation)
Maready, 362 N.C. 614 (2008) (distinguishes situations where informant credibility is established by observation)