708 S.E.2d 217
S.C.2011Background
- At ~2:50 a.m., officer Futch observed Corley drive to a known drug house and linger briefly before leaving.
- Corley failed to use a turn signal, prompting a traffic stop and request for license, registration, and insurance.
- During the stop, Corley appeared nervous and provided evasive answers, leading Futch to question him about his presence in the neighborhood.
- Corley admitted purchasing crack cocaine from the nearby drug house shortly before the stop.
- Corley moved to suppress his statements and the drugs; the trial court denied the motion and he was convicted; the Court of Appeals affirmed.
- The Supreme Court granted certiorari and affirmed the Court of Appeals as modified, holding the stop based on reasonable suspicion rather than probable cause.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was probable cause for the stop. | Corley—probable cause did not exist. | State—probable cause existed to stop. | No probable cause; stop justified by reasonable suspicion. |
| Whether the stop was valid on reasonable suspicion. | Corley contends only a stop for investigation was improper. | State—reasonable suspicion supported brief detention. | The stop was justified by reasonable suspicion. |
| Whether the traffic violation independently justified the stop. | Independent basis insufficient to justify stop. | Traffic violation provided an independent basis for the stop. | Yes; the traffic violation served as an independent basis for the stop. |
Key Cases Cited
- State v. Foster, 269 S.C. 373 (1977) (reasonable suspicion permits brief detention for investigation)
- State v. Woodruff, 344 S.C. 537 (Ct.App.2001) (reasonable suspicion requires a particularized and objective basis)
- U.S. v. Mason, 628 F.3d 123 (4th Cir.2010) (motorist behavior can create reasonable suspicion)