State v. Smathers, 753 S.E.2d 380

defendant Smathers struck a large animal with her vehicle at night on Highway 280 and continued driving.
Officer Kreigsman stopped Smathers to check safety after the collision; Smathers did not stop immediately.
Officers detected the scent of alcohol, glassy eyes, and slurred speech; Smathers failed roadside sobriety tests.
Smathers provided a positive breath test; blood alcohol concentration later measured at .18.
Smathers pled guilty to driving while impaired in District Court and appealed the suppression ruling.
The trial court denied the suppression motion; the Court of Appeals upheld that denial, recognizing the community caretaking doctrine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was reasonable under the community caretaking doctrine	State argues caretaking justification supports seizure	Smathers contends no reasonable suspicion or exigent basis	Yes; stop validated under community caretaking doctrine

State v. Styles, 362 N.C. 412 (2008) (traffic stop seizures; general doctrine context)
State v. Phillips, 151 N.C. App. 185 (2002) (probable cause not always required for traffic stops)
State v. Nowell, 144 N.C. App. 636 (2001) (warrantless searches; exemptions burden on State)
Cady v. Dombrowski, 413 U.S. 433 (1973) (establishes community caretaking rationale)
Kramer, 759 N.W.2d 608 (Wis. 2009) (three-part Wisconsin test for community caretaking)
State v. Barnard, 362 N.C. 244 (2008) (objective reasonableness; Terry context in NC)
State v. Heien, 366 N.C. 271 (2012) (objective reasonableness; officer mistake of law)