Williams v. State
317 Ga. App. 658
Ga. Ct. App.2012Background
- Bib County HEAT unit conducted sobriety checkpoints and staged a roadblock during late night hours of Nov. 27–28, 2010.
- Williams was stopped at approximately 2:00 a.m. and arrested for DUI and open container violations.
- Williams appealed the denial of his motion to suppress evidence from the roadblock, arguing the roadblock was implemented by a field officer rather than supervisory, programmatic action.
- The appellate standard requires reviewing the trial court’s findings for clear error and applying law to undisputed facts de novo.
- Georgia law allows roadblocks only if implemented at the programmatic level by supervisory personnel for a legitimate primary purpose, per Edmond and LaFontaine criteria.
- Evidence showed Jordan, a supervisory officer, authorized and helped conduct the roadblock, raising questions about whether the roadblock met the programmatic-level requirement but the court ultimately affirmed suppression denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the roadblock decision made by supervisory personnel? | Williams: Jordan, though supervisory, actually participated in roadblock, so not supervisory. | State: Jordan acted as supervisor, authorized roadblock in advance, and supervised the operation. | Yes; Jordan qualified as supervisor despite on-scene participation. |
| Was the roadblock implemented at the programmatic level for a legitimate primary purpose? | Williams: No written program guidance; roadblock shows pretext rather than safety purpose. | State: Jordan authorized roadblock for sobriety/checkpoint purposes under HEAT unit mission. | Yes; implemented at programmatic level with legitimate primary purpose. |
| Is the roadblock reasonable under the totality of the circumstances? | Williams: Roadblock gave officers unfettered discretion and burdened citizens arbitrarily. | State: No demonstrated unconstitutional burden; reasonable under totality. | Yes; not an unreasonable seizure; suppression denied. |
Key Cases Cited
- City of Indianapolis v. Edmond, 531 U.S. 32 (2000) (decision requiring programmatic-level purpose for roadblocks)
- LaFontaine v. State, 269 Ga. 251 (1998) (five criteria for roadblock constitutionality at programmatic level)
- Baker v. State, 252 Ga. App. 695 (2001) (supervisor's authority may be shown by plan/authorization even without written policy)
- Gonzalez v. State, 289 Ga. App. 549 (2008) (supervisory officer who participates at roadblock can still act in supervisory role)
- Jacobs v. State, 308 Ga. App. 117 (2011) (evidence of supervisory role can be established without formal written guidelines)