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708 S.E.2d 217
S.C.
2011
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Background

  • 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)
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Case Details

Case Name: State v. Corley
Court Name: Supreme Court of South Carolina
Date Published: Apr 4, 2011
Citations: 708 S.E.2d 217; 392 S.C. 125; 2011 S.C. LEXIS 107; 26957
Docket Number: 26957
Court Abbreviation: S.C.
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