State v. Williams
366 N.C. 110
| N.C. | 2012Background
- Williams arrested in Iredell County after 65 pounds of marijuana found in SUV she traveled in.
- Stop on I-77 for window tint violation; Perez drove the SUV and Williams was passenger.
- Vehicle owned by a third party; Williams produced IDs from Arizona and Texas.
- Perez and Williams provided inconsistent statements about origin and destination; attempts to clarify origin led to further questioning.
- Canine unit later alerted to drugs after Perez declined consent to search; search yielded marijuana.
- Trial court denied motion to suppress; intermediate appellate court affirmed; NC Supreme Court affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was reasonable suspicion to extend the stop. | Williams contends no reasonable suspicion. | State argues totality of circumstances supported suspicion. | Yes; reasonable suspicion existed to extend the stop. |
| Whether trial court findings 4–5 are supported by competent evidence. | Williams argues those findings are not adequately supported. | State argues findings are supported by competent evidence. | Yes; findings 4–5 are supported. |
| Whether misstatement about licenses affected the suppression ruling. | Williams notes error but argues it was not outcome-determinative. | State maintains it was not outcome-determinative. | No; error not outcome-determinative. |
Key Cases Cited
- Illinois v. Caballes, 543 U.S. 405 (U.S. 2005) (discussion of routine stop and post-stop detention length)
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (limits on detentions during traffic stops; need for reasonable suspicion for further detention)
- United States v. Cortez, 449 U.S. 411 (U.S. 1981) (totality-of-the-circumstances approach to reasonable suspicion)
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (affirmative use of totality-of-circumstances in reasonable suspicion)
- Sokolow, 490 U.S. 1 (U.S. 1989) (recognition that combined facts may create reasonable suspicion)
- Wardlow, 528 U.S. 119 (U.S. 2000) (clarifies boundaries of reasonable suspicion under totality framework)