State v. Jordan
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During an investigation of a stolen car, law enforcement officers followed a suspect into a nearby home where they discovered an illegal drug operation. One of the participants in the operation, the defendant, did not live at the residence and denied any ownership or control over the premises or the objects within, including a safe containing illegal items. The homeowner, who was also the defendant's uncle, consented to the search of the home. After the defendant was convicted of several drug-related offenses, he appealed, arguing that the evidence should have been suppressed because the police entered the home without a warrant.
The Supreme Court of North Carolina was tasked with deciding if the defendant had standing to challenge the warrantless entry into the home, given that he had declared he did not live there. The Court of Appeals had previously reversed the trial court's denial of the motion to suppress, stating that the trial record did not support any finding that the defendant lacked a reasonable expectation of privacy in the home.
The Supreme Court of North Carolina reversed the decision of the Court of Appeals, holding that the evidence presented at the suppression hearing could support findings that the defendant lacked standing to challenge the search. The court, however, noted that the trial court failed to make these findings despite the presence of materially conflicting evidence in the trial record. The case was remanded to the trial court for findings of fact based on the trial record. Depending on those findings, the trial court could again deny the motion to suppress, or it may grant the motion to suppress in whole or in part and order a new trial.
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