707 S.E.2d 451
S.C. Ct. App.2011Background
- Corporal Crompton stopped Wallace on Interstate 85 for driving left of center line and conducted a traffic stop lasting about twelve minutes; during the stop he observed factors prompting suspicion of serious criminal activity.
- Although Crompton issued a traffic ticket, he continued questioning Wallace and sought consent to search the car, which Wallace refused repeatedly.
- Crompton called a drug-sniffing dog, detaining Wallace while the dog walked around the vehicle; the dog alerted on the driver’s door and the trunk, leading to a search.
- Upon pulling bags from the back, Wallace claimed ownership of a bag containing 752 grams of cocaine.
- After cocaine was found, Wallace was Mirandized by Sergeant Colegrove and admitted he had picked up the cocaine and was delivering it to someone in North Carolina; he was arrested and indicted for trafficking.
- The central legal question was whether Crompton’s detaining after the traffic stop was reasonable under the Fourth Amendment based on the totality of circumstances; Wallace also challenged the admissibility of his pre-search statement and sought a mistrial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the post-stop detention was supported by reasonable suspicion. | Wallace argues there was no reasonable suspicion to detain. | Wallace contends Crompton’s observations were insufficient for continued detention. | Yes; the detention was supported by reasonable suspicion under the totality of the circumstances. |
| Whether Wallace’s statement identifying the bag as his was preserved for review. | Wallace challenge to admission of the statement was preserved. | The issue was not preserved because evidence was presented before objection. | Not preserved for review. |
| Whether the trial court abused its discretion in denying a mistrial. | Wallace argues mistrial was warranted due to replayed footage. | The judge acted within discretion; error was harmless since Wallace admitted the conviction. | Within discretion; no abuse of discretion. |
Key Cases Cited
- State v. Willard, 374 S.C. 129 (Ct.App.2007) (consideration of totality of circumstances; innocent travel factors can form reasonable suspicion)
- State v. Tindall, 388 S.C. 518 (2010) (detention after traffic stop requires reasonable suspicion of a serious crime)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (reasonable suspicion as a commonsense, nontechnical concept)
- United States v. McCoy, 513 F.3d 405 (4th Cir.2008) (reasonable suspicion depends on facts and context (Ornelas))