State v. Otto
366 N.C. 134
| N.C. | 2012Background
- State seeks review of a divided Court of Appeals ruling reversing a suppression denial.
- Trooper observed a burgundy Ford Explorer weaving within its lane for about three-quarters of a mile, stopping the vehicle at night (about 11:00 p.m.).
- Rock Springs Equestrian Center near the stop was hosting a Ducks Unlimited Banquet; trooper had heard it serves alcohol.
- Trial court denied suppression; defendant pleaded guilty to driving while impaired and reserved the right to appeal.
- Court of Appeals reversed on the factual finding that the trooper knew Rock Springs served alcohol; NC Supreme Court held there was reasonable suspicion for the stop and affirmed denial of suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion to justify the stop based on weaving within the lane? | Otto argues weaving alone is insufficient. | Otto argues weaving without additional factors is not enough. | Yes, there was reasonable suspicion. |
| Did the trial court correctly find that the trooper knew alcohol was served at Rock Springs? | Otto contends the trooper’s knowledge was not established. | Otto contends the knowledge was not proven; not binding on appeal. | Finding not binding; knowledge shown was not established but need not determine suppression. |
| Should the Court apply the totality-of-the-circumstances standard to assess reasonable suspicion? | Totality supports insufficiency if weaving is sole factor. | Totality supports reasonable suspicion due to continuous weaving and timing. | Totality supports reasonable suspicion. |
| Did the Court of Appeals err in reversing the suppression ruling? | Weaving alone could justify stop under totality. | Court of Appeals erred by requiring more than weaving. | Court of Appeals reversed correctly; stop was supported by reasonable suspicion. |
Key Cases Cited
- State v. Styles, 362 N.C. 412 (2008) (reasonable suspicion framework for traffic stops; totality of circumstances)
- State v. Biber, 365 N.C. 162 (2011) (standard for reviewing suppression findings)
- Terry v. Ohio, 392 U.S. 1 (1968) (reasonable suspicion standard; minimal objective justification)
- Ornelas v. United States, 517 U.S. 690 (1996) (deference to inferences drawn by local officers; community context)
- State v. Jacobs, 162 N.C.App. 251 (2004) (weaving in lane near bars as basis for suspicion)
- State v. Fields, 195 N.C.App. 740 (2009) (weaving in lane at 4:00 p.m. not sufficient without more)
- State v. Peele, 196 N.C.App. 668 (2009) (single weaving instance not always sufficient)