Williams v. State
293 Ga. 883
Ga.2013Background
- James Kemp Williams was stopped and arrested at a Bibb County sobriety checkpoint and moved to suppress evidence as an unconstitutional roadblock seizure.
- BCSO’s written checkpoint policy consisted of two sentences authorizing “general roadblocks which serve legitimate law enforcement purposes”; no broader written limitations were introduced at trial.
- Sergeant Bruce Jordan, supervisor of a three-officer HEAT unit, was authorized verbally by his captain to implement checkpoints and regularly conducted multiple checkpoints per week; he decided the November 27 checkpoint at or just before his shift and notified deputies in advance.
- At the checkpoint every vehicle was briefly stopped and screened; Williams was screened, admitted drinking, refused further breath testing/field tests, and was arrested—the only arrest from that checkpoint.
- Trial court denied suppression finding LaFontaine requirements met and the checkpoint a legitimate sobriety operation; Court of Appeals affirmed; Georgia Supreme Court granted certiorari.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (State/BCSO) | Held |
|---|---|---|---|
| Was the decision to implement the checkpoint made by supervisory personnel (LaFontaine prong 1)? | Jordan acted as a field officer; checkpoints were effectively initiated in the field. | Jordan was the HEAT unit supervisor, decided time/place in advance, and had delegated authority to implement checkpoints. | Held: Trial court finding that Jordan implemented the checkpoint in his supervisory capacity is supported by evidence; LaFontaine prong 1 satisfied. |
| Did the BCSO checkpoint program have an appropriate primary purpose other than general crime control (Edmond programmatic inquiry)? | The program served sobriety/traffic safety; checkpoint here was a sobriety checkpoint. | BCSO policy and practice authorized “general roadblocks” and lacked programmatic limits excluding general crime control. | Held: State failed to prove the checkpoint program had a primary purpose other than ordinary crime control; Edmond not satisfied. |
| Did the checkpoint comply with LaFontaine’s remaining requirements (stopping all vehicles, minimal delay, identification, screener training)? | N/A (Williams did not contest these four requirements). | State presented evidence checkpoint met LaFontaine’s other four requirements. | Held: Court accepted compliance with the other four LaFontaine factors. |
| Was suppression nonetheless required under the totality of the circumstances? | The programmatic deficiency and routine/unregulated use made stops arbitrary/oppressive. | If LaFontaine factors are met and purpose was sobriety, stop was reasonable. | Held: Because Edmond programmatic requirement failed, suppression required; court did not reach broader totality analysis. |
Key Cases Cited
- Brown v. State, 293 Ga. 787 (Ga. 2013) (clarifies bifurcated analysis: Edmond programmatic primary-purpose inquiry distinct from LaFontaine supervisor-implementation inquiry)
- LaFontaine v. State, 269 Ga. 251 (Ga. 1998) (identifies five minimum requirements for checkpoint constitutionality)
- City of Indianapolis v. Edmond, 531 U.S. 32 (U.S. 2000) (holds checkpoint programs cannot be primarily for general crime control)
- Williams v. State, 317 Ga. App. 658 (Ga. Ct. App. 2012) (Court of Appeals decision affirming trial court; reviewed on certiorari)
- Baker v. State, 252 Ga. App. 695 (Ga. Ct. App. 2001) (discussed by courts regarding supervisory/programmatic distinctions in checkpoint cases)