State v. Woolard
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In North Carolina, Melvin Woolard Jr. was arrested by Captain Rodney Sawyer for driving while impaired (DWI). Before his trial, Mr. Woolard filed a motion to suppress evidence seized during the arrest, arguing that the officer lacked probable cause to suspect him of drunk driving. The District Court agreed and granted his motion. The State appealed the decision to the Superior Court, which also found that the arrest violated the Fourth Amendment. The case was then taken to the Supreme Court of North Carolina.
The Supreme Court of North Carolina examined the evidence and found that Captain Sawyer had probable cause to arrest Mr. Woolard for impaired driving. The court noted that Mr. Woolard had been driving erratically, swerving over the centerline multiple times, and veering onto the road's shoulder. Additionally, the officer smelled alcohol on Mr. Woolard's breath and inside his truck, observed his red and glassy eyes, and heard his admission to having consumed some beers before driving. Mr. Woolard also exhibited all six possible indications of impairment on a Horizontal Gaze Nystagmus (HGN) test administered by the officer.
Based on these facts, the court concluded that an objectively reasonable officer in Captain Sawyer’s position would have suspected Mr. Woolard of impaired driving. Consequently, Mr. Woolard’s arrest satisfied the Fourth Amendment. The court therefore reversed the District Court's decision to suppress the evidence and remanded the case for further proceedings.
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