State v. Alvarez
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The Supreme Court of North Carolina heard a case regarding a traffic checkpoint where the defendant, Alvarez, was stopped, searched, and found in possession of illegal drugs. He moved to suppress the evidence, arguing that it was collected at an unconstitutional checkpoint. The trial court agreed with the defendant, ruling that the checkpoint violated the Fourth Amendment as the State failed to provide a valid primary programmatic purpose for it. The Court of Appeals affirmed this decision.
However, the Supreme Court of North Carolina disagreed, holding that the officers at the checkpoint had an independent reasonable suspicion to stop Alvarez's vehicle, thus no violation of his Fourth Amendment rights occurred. This suspicion was based on Alvarez's behavior and driving, including his failure to maintain lane control. The court emphasized that reasonable suspicion is an issue separate from the constitutionality of the checkpoint.
The court concluded that the trial court erred in granting the motion to suppress and that the Court of Appeals erred in affirming the trial court's order. As a result, the court reversed the decision of the Court of Appeals and remanded the case for further proceedings. The court declined to comment on the constitutionality of the traffic checkpoint due to the presence of independent reasonable suspicion.
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