State v. Williams
215 N.C. App. 1
| N.C. Ct. App. | 2011Background
- Sgt. Cass stopped a tinted SUV on I-77 due to NC tint law; Perez drove, Defendant passenger; Perez claimed they were coming from Houston and going to Myrtle Beach, while Defendant claimed origin from Louisville and ownership by a friend; BLOC check found nothing adverse; canine alerted to marijuana after alert following a warning; search of SUV revealed large quantity of marijuana; Defendant was charged with trafficking based on possession and transport; motion to suppress denied; Defendant pleaded guilty to one count and was sentenced; issue on appeal is whether suppression denial was proper.
- Perez and Defendant gave conflicting origin/destination information and ownership claims, creating a basis for reasonable suspicion to extend detention after the initial stop.
- The suppression hearing record included audio of the stop and BLOC verification; trial court made findings of fact 4, 5, and 9 which are central to whether the detention was justified.
- The Court of Appeals affirmed the denial of suppression; Judge McGee dissented, arguing the findings did not establish reasonable suspicion.
- The dispositive issue on appeal was whether the extended detention lacked reasonable suspicion and thus violated the Fourth Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonable suspicion for extended detention | Williams argues findings do not show reasonable suspicion | Williams contends inconsistencies and uncertainties negate suspicion | Extended detention supported by reasonable suspicion |
| Support for Findings 4, 5, and 9 | Findings are supported by competent evidence | Findings misstate or overstate evidence (especially ownership/docs) | Findings 4 and 5 supported; Finding 9 de minimis; no material conflict undermining conclusions |
| Preservation of appeal rights | Appeal properly noted | Record insufficient to prove notice of appeal | Appeal rights preserved; proper notice deemed shown by trial court actions |
Key Cases Cited
- Falana v. State, 129 N.C.App. 813 (1998) (reasonable-suspicion framework; totality of circumstances)
- Myles v. State, 188 N.C.App. 42 (2008) (extended detention requires reasonable suspicion; nervousness alone insufficient)
- McClendon v. State, 350 N.C. 630 (1999) (factors forming reasonable suspicion; conflicts resolved by court)
- Pearson v. State, 348 N.C. 272 (1998) (nervousness and conflicting travel details insufficient alone; supports suppression)
- McArn v. State, 159 N.C.App. 209 (2003) (police must resolve conflicts; factual findings control legal conclusions)
- State v. Watkins, 337 N.C. 437 (1994) (totality-of-circumstances approach to reasonable suspicion; articulable facts)
- United States v. Cortez, 449 U.S. 411 (1981) (totality of the circumstances standard for reasonable suspicion)
- Royer v. Florida, 460 U.S. 491 (1983) (stop and subsequent questioning require reasonable suspicion)
- State v. McArn, 582 S.E.2d 371 (2003) (clarifies suppression review standards)
- State v. Falana, 501 S.E.2d 358 (1998) (illustrates limitations of factors contributing to reasonable suspicion)