State v. Osterhoudt, 222 N.C. App. 620

The State appeals a 14 March 2011 superior court order affirming a district court pretrial indication granting defendant Osterhoudt’s motion to suppress evidence from a traffic stop.
Trooper Monroe observed defendant’s vehicle stray over the double yellow line while turning right onto Fifth Street, a three-lane road, and stopped him.
District court concluded the crossing of the double yellow line did not violate traffic laws and that the stop was unreasonable under the Fourth Amendment.
Superior court found that defendant’s car crossed the line but never crossed the middle halfway point of Fifth Street, and held the stop was unlawful.
The State challenged these conclusions on appeal, arguing errors of fact, legal standards, and Fourth Amendment analysis; the court reversed and remanded for a final order denying suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the finding that defendant never crossed the middle point of Fifth Street supported?	State contends evidence does not prove no crossing.	Osterhoudt contends finding is supported by Monroe’s testimony.	Yes; finding supported by competent evidence.
Did crossing the double yellow line violate traffic laws as applied here?	State asserts defendant violated applicable statutes.	Osterhoudt argues centerpoint rule excuses violations.	crossed 20-146(d)(1) and (d)(3-4); 20-153; centerpoint rationale rejected.
Did the superior court improperly rely on normal driving to determine Fourth Amendment reasonableness?	State argues reliance on normal driving undermines objective suspicion.	Osterhoudt accepts totality but disputes sole focus on normal driving.	Court held need for objective criteria; remand for final order denying suppression.

State v. Cooke, 306 N.C. 132 (1982) (standard for reviewing suppression orders on appeal)
State v. Styles, 362 N.C. 412 (2008) (reasonable suspicion standard for traffic stops; totality considerations)
State v. Watkins, 337 N.C. 437 (1994) (objective facts and rational inferences for stops; minimal justification)