Tuesday, April 19, 2016

Is HGN enough to Arrest for DWI

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I have a case scheduled for trial this week in Wake County.  The only portion of the Field Sobriety Test my client failed was the HGN test where he had 4 of 6 clues.  He did great on all other parts of the test.  The question is whether or not this sole factor is sufficient to create probable cause to arrest.  Below is the relevant case law.

An unpublished opinion of the North Carolina Court of Appeals does not constitute
controlling legal authority. Citation is disfavored, but may be permitted in accordance
with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.



                                NO. COA14-269
                       NORTH CAROLINA COURT OF APPEALS

                              Filed:    6 January 2015


STATE OF NORTH CAROLINA

      v.                                      Durham County
                                              No. 12 CRS 61669
MARGARET K. SEWELL



      Appeal by the State from order entered 3 October 2013 by

Judge Carl R. Fox in Durham County Superior Court.                  Heard in the

Court of Appeals 27 August 2014.


      Attorney General Roy Cooper, by Assistant Attorney General
      Joseph L. Hyde, for the State.

      Kimberly P. Hoppin, for defendant-appellee.


      CALABRIA, Judge.


      The State appeals, pursuant to N.C. Gen. Stat. § 15A-979

and § 15A-1445,        from an order granting Margaret K. Sewell’s

(“defendant”)      motion    to   suppress    evidence     gathered      after   her

arrest     and   dismissing    the     offense   of   driving    while    impaired

(“DWI”).     We affirm in part and reverse in part.

                                  I. Background

      On the evening of 16 November 2012, the North Carolina
                                        -2-
State     Highway   Patrol       (“NCSHP”)     conducted       a     checkpoint     on

University Drive at the entrance to Forest Hills Park in Durham,

North Carolina.         The checkpoint’s primary purpose was to check

for DWI offenses.          Sergeant Maurice Devalle (“Sgt. Devalle”)

supervised the checkpoint, which was conducted pursuant to a

written authorization form and NCSHP policy.                    In addition, the

checkpoint was marked by patrol vehicles with their blue lights

activated,     troopers        participating       in   the        checkpoint      wore

reflective     vests     and    held   flashlights,      and       every    car    that

approached the checkpoint was checked.

    Shortly      after    midnight     on    17    November     2012,      defendant,

driving    a   Toyota    sport    utility    vehicle     with       one    passenger,

approached the checkpoint.             When NCSHP Trooper Jeremy Doston

(“Trooper      Doston”)         requested         defendant’s        license        and

registration, he detected a strong odor of alcohol emanating

from defendant’s vehicle.          Although Trooper Doston observed that

defendant’s     eyes     were    red   and   glassy,     her       speech    was    not

slurred, and she retrieved her license and registration without

difficulty.      Defendant initially denied drinking alcohol that

evening, but later admitted to drinking a glass of wine.

    Trooper Doston requested that defendant exit her vehicle

and perform a series of field sobriety tests.                        Trooper Doston

observed that defendant exhibited no clues of intoxication on
                              -3-
either the “One-Leg Stand” test or the “Walk and Turn” test.

However,       defendant    displayed            six    out    of    six       clues    on    the

horizontal      gaze     nystagmus            test    (“HGN    test”).          In   addition,

defendant performed two Alco-sensor breath tests, both of which

indicated       that    defendant’s            breath     tested       positive        for    the

presence of alcohol.                As a result, defendant was arrested and

charged with DWI.

       Defendant subsequently pled guilty to DWI in Durham County

District     Court.        On       16   May    2013,    the     trial     court       sentenced

defendant to sixty days in the custody of the Sheriff of Durham

County,      suspended      defendant’s              sentence,      and    placed       her    on

unsupervised probation for twelve months.                         Defendant appealed to

Durham County Superior Court for a trial de novo.

       On 11 August 2013, defendant filed a pretrial motion to

suppress all evidence gathered after the stop of her vehicle and

after her arrest.           After a hearing, where both Trooper Doston

and Sgt. Devalle testified, the trial court entered an order on

3    October    2013    granting         defendant’s          motion      to    suppress      and

dismissed defendant’s DWI offense.                     The State appeals.

                                II. Motion to Suppress

       “In     evaluating       a    trial      court’s       ruling      on    a    motion    to

suppress . . . the trial court’s findings of fact are conclusive

on    appeal    if     supported         by    competent       evidence,        even     if   the
                                       -4-
evidence is conflicting.”           State v. Allen, 
197 N.C. App. 208
,

210, 
676 S.E.2d 519
, 521 (2009) (citation omitted).                             Findings

not   challenged     on   appeal    are    deemed          supported      by   competent

evidence and are binding on appeal.                    State v. Biber, 
365 N.C. 162
, 168, 
712 S.E.2d 874
, 878 (2011).                      “Conclusions of law are

reviewed de novo[.]”        Id.

       As an initial matter, since the State does not challenge

the trial court’s findings, they are binding on appeal.                                 Id.

Neither party contests the validity of the checkpoint on appeal.

Rather, the State argues that the trial court erred in granting

defendant’s     motion    to    suppress        because      the   totality       of    the

circumstances indicate that Trooper Doston had probable cause to

arrest defendant for DWI.           Therefore, we must determine whether

Trooper Doston lacked probable cause to arrest defendant, and

whether the trial court properly granted defendant’s motion to

suppress.

       “Probable cause requires only a probability or substantial

chance   of    criminal     activity,     not     an    actual     showing       of    such

activity.”      State     v.   Teate,     180    N.C.      App.    601,    606-07,      
638 S.E.2d 29
, 33 (2006) (quoting Illinois v. Gates, 
462 U.S. 213
,

244 n.13, 
76 L. Ed. 2d 527
, 552 n.13 (1983)).                    “Probable cause for

an    arrest   has   been      defined    to     be    a    reasonable         ground    of

suspicion, supported by circumstances strong in themselves to
                               -5-
warrant a cautious man in believing the accused to be guilty.”

Id.   at   607,     638   S.E.2d     at    33    (citation       omitted).          “Whether

probable      cause    exists      to     justify      an     arrest    depends      on     the

‘totality of the circumstances’ present in each case.”                              State v.

Sanders, 
327 N.C. 319
, 339, 
395 S.E.2d 412
, 425 (1990), cert.

denied, 
498 U.S. 1051
, 
112 L. Ed. 2d 782
 (1991).

       The State relies in part upon State v. Rogers, 124 N.C.

App. 364, 
477 S.E.2d 221
 (1996), superseded by statute as stated

in    State   v.    Overocker,      ___     N.C.       App.    ___,    
762 S.E.2d 921
,

(2014), to support its argument that Trooper Doston had probable

cause to arrest defendant for DWI.                          In Rogers, the defendant

stopped his vehicle in the middle of an intersection to ask the

trooper    directing        traffic      for    directions.            Id.    at    366,    477

S.E.2d at 222.        The trooper detected a strong odor of alcohol on

the defendant’s breath, and administered one Alco-sensor test

before arresting the defendant.                  Id.     The trial court denied the

defendant’s motion to suppress.                    Id.        On appeal from his DWI

judgment,     this    Court       held    that    while       the   trooper        failed    to

administer the Alco-sensor test twice, as required by statute,

the trooper did not rely solely on the odor of alcohol. Id. at

369-70,    477     S.E.2d    at    224.        This     Court    concluded         there    was

adequate evidence to support a finding of probable cause                                     to

arrest     the     defendant.       Id.         The    trooper      not      only   had     the
                                           -6-
opportunity    to    consider     the     defendant’s      .13   Alco-sensor     test

result,1 but also to observe and speak with the defendant. Id. at

370, 477 S.E.2d at 224.             Therefore, the trial court properly

denied the defendant’s motion to suppress.                 Id.

       The   facts   in   the    instant    case     are   distinguishable      from

Rogers.      The defendant in           Rogers   initiated contact with the

arresting officer by stopping the vehicle he was driving in the

middle of the intersection, and the trooper detected a strong

odor of alcohol emanating from the defendant, who was the sole

occupant of the vehicle.             In the instant case, defendant was

stopped at a checkpoint, had not displayed any bad driving or

violated any motor vehicle laws, and the strong odor of alcohol

that   Trooper     Doston      detected    was    emanating      from   defendant’s

vehicle, not from defendant, who was accompanied by a passenger.

       According     to   the    trial     court’s    findings     in    the   order

regarding     defendant’s        motion     to     suppress,      Trooper      Doston

observed defendant’s red, glassy eyes and defendant exhibited

six of six clues on the HGN test, as well as positive results

for    the   presence     of    alcohol    on    defendant’s     two    Alco-sensor

breath tests.        However,      Trooper Doston did not testify that

1
  The statutory language that allowed the arresting officer in
Rogers to consider the numerical reading of the Alco-sensor test
was superseded by statute as noted in State v. Overocker, ___
N.C. App. ___, ___, 
762 S.E.2d 921
, 929 (2014).    See N.C. Gen.
Stat. § 20-16.3(d) (2013).
                               -7-
defendant herself was the source of the odor of alcohol.                        The

trial court also found that defendant’s speech was not slurred,

she   retrieved     and   provided   Trooper      Doston    with   her    driver’s

license and registration without any difficulty or delay, and

she was steady on her feet when Trooper Doston requested that

she exit her vehicle.           In addition, defendant followed Trooper

Doston’s instructions at all times, and was polite, cooperative,

and respectful to him during their encounter.                  The trial court

further found that defendant exhibited no clues of intoxication

on the “One-Leg Stand” and “Walk and Turn” tests.                        The trial

court concluded, “[t]he facts and circumstances known to Trooper

Dotson [sic] as a result of his observations and testing of the

Defendant      were    insufficient,     under      the     totality      of    the

circumstances, to form an opinion in the mind of a reasonable

and   prudent     man/officer     that   there     was     probable    cause”    to

believe defendant had committed the offense of DWI, and granted

defendant’s motion to suppress.

      The   trial     court’s   unchallenged      findings,    based     upon   the

totality of the circumstances, show that the circumstances were

not   strong    enough    in    themselves   to    warrant     probable     cause.

Since there was no probable cause to support defendant’s arrest,

and the trial court’s findings support its conclusions of law,
                                            -8-
we   therefore      hold    that     the     trial     court    properly     granted

defendant’s motion to suppress.

                            III. Motion to Dismiss

     The    State    also    argues    that     the     trial    court     erred   in

granting a motion to dismiss.              We agree.

            The granting of a motion to suppress does
            not mandate a pretrial dismissal of the
            underlying   indictments.      The   district
            attorney may elect to dismiss or proceed to
            trial without the suppressed evidence and
            attempt to establish a prima facie case. If
            so, a defendant may move to dismiss at the
            close of the State’s evidence and renew his
            motion at the close of all evidence.

State v. Edwards, 
185 N.C. App. 701
, 706, 
649 S.E.2d 646
, 650

(2007) (citing N.C. Gen. Stat. § 15-173 (2005)).

     In    the    instant    case,    defendant        moved    to   suppress      the

evidence obtained subsequent to her arrest, and the trial court

granted    her    motion.     However,        defendant’s       appellate    counsel

concedes that the record does not indicate that defendant made a

motion to dismiss, and her case was still in the pretrial stage.

Therefore, pursuant to Edwards, the State, not the trial court,

had the option to either dismiss the DWI offense or proceed to

trial without the suppressed evidence and attempt to establish a

prima     facie   case.       Therefore,        the    trial     court     erred    in

dismissing defendant’s DWI offense.

                               IV. Conclusion
                             -9-
    Under the totality of the circumstances, the trial court

properly      concluded    that       Trooper    Doston     lacked       sufficient

probable cause to arrest defendant for the offense of DWI, and

therefore      correctly   granted      defendant’s       motion    to    suppress.

However, the trial court erred in dismissing the DWI offense as

a result of the pretrial motion to suppress.                       Therefore, we

affirm   the    portion    of   the    trial    court’s    order    granting    the

motion   to    suppress,    but   reverse       the   portion      of    the   order

dismissing the matter.

    Affirmed in part, reversed in part.

    Judges ELMORE and STEPHENS concur.

    Report per Rule 30(e).
 

Tuesday, April 12, 2016

Is Bad Driving Against the Law

Image result for bad driving
www.kisslinglaw.com

Great review of a new decision on Unsafe Movement from the NC School of Government.

hat’s my take-away from State v. Johnson, decided by the court of appeals last week.
Facts. Johnson began at 10:00 one February evening in Hendersonville. Snow had just begun to fall. An officer was stopped at a red light when the defendant pulled up next to the officer in a left-turn lane. The defendant was blaring his music and revving his engine. When the light turned green, the defendant accelerated into a left turn, screeching his tires and fishtailing his truck. The vehicle did not contact the sidewalk and stayed within the proper lane of travel. There were no pedestrians or other vehicles in the area. The officer stopped the defendant for unsafe movement for the conditions of the roadway. The defendant turned out to be impaired and was charged with DWI.
Procedural history. The defendant moved to suppress, arguing that the stop was not based on reasonable suspicion. A district court judge preliminarily agreed, but on review, a superior court judge upheld the stop and remanded the case. The defendant pled guilty to DWI in district court and appealed to superior court. He again moved to suppress, and the motion was denied. He pled guilty and appealed to the appellate division.
Court of appeals opinion. The appellate court ruled unanimously that the officer lacked reasonable suspicion. It considered two statutes: G.S. 20-141(a), which prohibits driving at a speed “greater than is reasonable and prudent under the conditions then existing,” and G.S. 20-154(a), which prohibits “starting, stopping or turning from a direct line” without first “see[ing] that such movement can be made in safety.” (The court didn’t consider the reckless driving statute, G.S. 20-140, as a possible basis for the stop, perhaps because the officer’s explanation of the reason for the stop didn’t reference recklessness.)
The court observed that the defendant (1) stayed in his lane, (2) did not hit the sidewalk, (3) did not exceed any posted speed limit, and (4) did not risk a collision with another vehicle or a pedestrian. Therefore, it concluded that “[n]othing that . . . the trial court found that Defendant had done . . . constituted unsafe driving, as defined by our statutes, even factoring in the weather conditions.”
Analysis. I admit to being a little surprised by Johnson. I would have thought that a motorist who is going fast enough to fishtail his or her vehicle is going faster than is “prudent,” even if no one else is around and even if the driver is able to keep the vehicle in its lane. (Importantly, there does not seem to have been any suggestion that the road at issue in Johnson had a concealed defect, such as a patch of black ice, that would have caused even a cautious driver to lose traction.) See, e.g., State v. Thibault, 564 A.2d 603 (Vt. 1989) (affirming an unsafe movement conviction where the tires of the defendant’s vehicle squealed and spun, and stating that “the spinning of the tires made it unsafe to proceed while the tires were in spinning motion”).
But my surprise is neither here nor there. Assuming that Johnson isn’t reviewed further, it will be interesting to see how it applies to other driving behavior that seems risky to my middle-aged sensibilities but that may be accomplished in a single lane and below posted limits, such as drifting, burn-outs, and jackrabbit starts. It may also be worth noting that similar driving when other vehicles or pedestrians are nearby may have different consequences. See, e.g., State v. Duncan, 781 S.E.2d 531 (N.C. Ct. App. Jan. 5, 2016) (unpublished) (reasonable suspicion of reckless driving existed where the defendant revved his truck; fishtailed it while pulling out of a parking lot, lifting a tire off the ground; and slung gravel with pedestrians and other vehicles nearby).

Wednesday, March 30, 2016

DEATHS CAUSED BY UNDOCUMENTED DRIVERS

Image result for deaths caused by illegal immigrants

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Interesting article on deaths caused by illegal immigrants compared to DWIs.

In the five years since an unlicensed illegal immigrant ran down his son, Don Rosenberg has turned his anger and grief into a mission to answer a seemingly simple question: How many people are killed each year by drivers who don’t belong in the U.S., much less behind a wheel?
Drew Rosenberg, a 25-year-old student at Golden Gate University, was riding his motorcycle in San Francisco when Roberto Galo struck him on Nov. 16, 2010. In his frenzied effort to flee the scene, Galo ran over his victim twice. The elder Rosenberg got the news no parent should hear from San Francisco General Hospital that night, but what he would learn over the next few years only compounded his bitterness.
As many as 7,500 Americans -- 20 per day -- are killed annually by unlicensed drivers, and Rosenberg calculates that more than half are the victims of illegal immigrants. Now, by testifying before lawmakers, speaking to parents who have been through the same ordeal and posting his research on his nonprofit’s website, unlicensedtodrive.org, Rosenberg is shedding light on a frightening number not readily available from government sources.
“Our archives are filled with stories of drunk-driving illegals killing U.S. citizens.”
- William Gheen, Americans for Legal Immigration
“I was stunned at what I found,” said Rosenberg, who at 63 is semi-retired from the entertainment and publishing industry. “Not only were unlicensed drivers killing people in numbers only exceeded by drunk drivers, but many times they were barely being punished and many times faced no charges at all.”
Galo, a Honduran, who entered the country illegally but earned temporary protective status, had been cited five months earlier for driving without a license or insurance and heading the wrong way on a one-way street in San Francisco. His car was impounded for a day, he paid a fine for the moving violation and the other charges were dropped.
After he was convicted of manslaughter, Galo served six weeks in jail and was released. He was deported in 2013 after a years-long legal battle.
Because state and federal highway safety officials do not classify deaths by the perpetrator’s immigration stats, tabulating the deadly toll of unlicensed, illegal immigrant drivers has been a painstaking effort.  Rosenberg has pored through spreadsheets and studies, piecing together numbers that show his son’s death was neither necessary nor unique. Still, his estimate is just that, and it varies from the guesses of other groups.
“I’ve learned over time that many jurisdictions do not cite license status or immigration status when reporting these statistics, so if anything, the numbers are understated,” he said. “For example, San Francisco doesn’t report either criteria, so Drew’s death defaults to having been killed by a licensed driver who was a citizen.”
Such imprecise government bookkeeping masks a frightening and, critics say, preventable danger. The AAA Foundation for Traffic Safety, which obtains state-by-state data from the federal government Fatality Analysis Reporting System (FARS) database – found that 20 percent of fatal crashes involved an unlicensed driver. From 2010-2014, there was an average of 32,887 road deaths per year, which would mean 6,577 were caused by unlicensed drivers. Those drivers include citizens with suspended or revoked licenses, and those who never had licenses. But if half are illegal immigrants, it would be in line with Rosenberg’s estimates.
“Our archives are filled with stories of drunk-driving illegals killing U.S. citizens,” William Gheen, of the Americans for Legal Immigration Political Action Committee, told FoxNews.com. “It is our official estimate that more than 3,000 U.S citizens lose their lives each year due to the insufficient enforcement of our existing border and immigration law.”
Brandon Mendoza was a 32-year-old, Mesa, Ariz., policeman in 2014 when an unlicensed, illegal immigrant driver drove drunk the wrong way on a freeway and killed him. Raul Silva-Corona had been convicted of criminal conspiracy in Colorado 20 years earlier, but never deported.
Mendoza’s mother believes the government could make the roads safer by at least deporting illegal immigrants who have been convicted of crimes.
“I don't believe it's reality to be able to get all of the illegals out of the country, but I do believe we need to get the criminal element out of here and secure the border so that they cannot continue to keep coming back,” Mary Ann Mendoza said.
Like Rosenberg, Mendoza has turned her grief into activism, starting a memorial foundation to continue her fallen son’s legacy and urging policymakers to take the issue more seriously.
“Until you have lost a loved one to an illegal criminal, you will never truly understand the other side of this issue,” she said.
The problem of unlicensed illegal immigrant drivers is most severe in the southwest, according to Peoria, Ariz., Police Detective Chris Boughey. Patrolling the streets of the Phoenix suburb, Boughey has encountered many incidents involving unlicensed, illegal immigrant drivers and considered it in a national perspective.
“With at least 11.4 million unauthorized immigrants in the United States, it can be surmised that a large population drive a vehicle on a regular basis,” Boughey said, adding that enforcing laws already on the books should mean deportation for illegal immigrants caught driving without valid licenses.
When government agencies do acknowledge the danger posed by unlicensed drivers, including illegal immigrants, they often use the information to further a pro-illegal immigrant agenda, say critics.
In the wake of a 2013 study by the California Department of Motor Vehicles that concluded that unlicensed drivers are almost three times as likely to cause a deadly car accident as a licensed driver, Gov. Jerry Brown signed legislation allowing illegal immigrants to obtain driver’s licenses. California, which was believed to have 2 million unlicensed drivers prior to passage of the law, is now one of a dozen states to allow the controversial practice.
“States that have worked with undocumented immigrants to enable them to get drivers licenses and insurance see a decrease in uninsured motorist claims,” said Janet Ruiz, of the Insurance Information Institute. “The availability of driver’s licenses and insurance promote safer driving and less accidents.”
Gregory Chen, director of advocacy at the American Immigration Lawyers Associated, agreed.
"The best way to ensure safety on our nation's roads is to make sure everyone who drives has passed a driver's exam, and has a license and insurance,” he said. “The last thing states and localities want is for their law enforcement and emergency teams to arrive at roadside accidents where drivers are uninsured and where injured persons arrive at hospitals unable to pay."
But Gheen and other critics say those who combat the problem of unlicensed drivers by awarding them licenses have it backward. A better solution, he said, is enforcing existing immigration law to the point that people are no longer encouraged to “enter and remain in the U.S. illegally.”
Rosenberg, who describes himself as a “lifelong liberal,” said the circumstances surrounding his son’s death have left him bitter at the group he calls the “amnesty crowd.” He also wants illegal immigrants caught driving without a license to be deported.
 “While I can sympathize with people who want to make their lives better, they can’t do it at the expense of others,” he said. “I am not angry at those who come here to try and better their life or their children’s, but it can’t be condoned or rewarded.”

Wednesday, March 23, 2016

HAPPY EASTER FROM LAW ENFORCEMENT


HAPPY EASTER FROM LAW ENFORCEMENT

Speeding enforcement crackdown in NC to target anyone going above posted limit

(WTVD)
(WTVD)
RALEIGH, N.C. — How fast can you go on the highway without getting the attention of police? Anything under 10 miles per hour over the speed limit is okay, right?
Well, WTVD reported that the North Carolina Department of Transportation is ready to burst the bubble on the widely believed 9 mph cushion myth.
The governor’s highway safety program is ramping up what’s being called “Obey the Sign or Pay the Fine” speeding enforcement crackdown.
Apparently, there’s a belief out there that if the speed limit is 65, officers or troopers won’t pull you over if you’re doing 1 to 9 miles per hour over the limit – a so-called buffer zone.
The DOT says that’s not the case. Law enforcement says beginning Thursday, they’ll target and ticket anyone driving above the posted speed limit.

Tuesday, March 15, 2016

Raleigh Traffic Stop

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The Raleigh Police Department recently put out a video on what to do in a traffic stop.  Below is a great review of the video from the NC School of Government.

As mentioned in a recent News Roundup, the Raleigh Police Department (RPD) produced a short video entitled “Traffic Stops: What to Expect as a Motorist,” instructing drivers who have been pulled over by law enforcement on how they should behave. It appears that the RPD had the laudable goal of educating the public to ensure the safety of both officers and motorists. Captain Bruce, the officer who narrates the video, states that “by following a few basic steps, the experience can progress without misunderstanding or conflict.” The video is garnering attention: As of today, it has received 8,446 views on YouTube, with “likes” outweighing “dislikes” 21 to 15. This blog offers legal commentary on a few of the points made in the video, using a scale of green light for what appear to be sound instructions, yellow light for instructions that may raise questions, and red light for an instruction that may prove misleading to citizens.


Stoplight Green
Standard for a traffic stop: The officer in the video correctly states that a traffic stop must be supported “by reasonable suspicion based on facts the officer can articulate.” While there was a line of North Carolina cases holding that a stop for a readily observable traffic stop must be supported by probable cause, those cases have been overruled. See State v. Styles, 362 N.C. 412 (2008). The stop depicted in the video is based on failure to stop at a stop sign, an infraction. G.S. 20-158(b)(1). The officer was justified in making the stop; I didn’t even see the car’s brake lights come on as the driver rolled through the stop sign and made a right turn. An officer might choose to give a warning rather than a citation as no cars or people were around and the driving wasn’t particularly risky, but the decision is up to the officer.
Stoplight YellowThe duty to answer the stopping officer’s questions: The officer tells viewers, “Answer any questions the officer may have fully and clearly.” This directive gives me pause. Under North Carolina law, a person operating a motor vehicle must identify himself or herself when requested by an officer (or, for that matter, when requested by any other person in the event of an accident). G.S. 20-29. Unlike some other states, North Carolina has not enacted “stop and identify” statutes when a person is not operating a motor vehicle. See In re D.B., 214 N.C. App. 489, 495 (2011). However, the North Carolina Court of Appeals has held that the failure to identify oneself during a lawful stop can constitute resisting an officer when it hinders the officer in issuing a citation or otherwise completing the stop. State v. Friend, ___ N.C. App. ___, 768 S.E.2d 146, 148 (2014) (trial court properly denied the defendant’s motion to dismiss the charge of resisting, delaying, or obstructing an officer where the defendant, a passenger, refused to provide the officer with his identification so that the officer could issue a citation for a seatbelt violation). The court recognized that Fifth Amendment protections may justify a refusal to provide one’s identity in some circumstances, but didn’t provide examples. Id.
Beyond identifying oneself and providing license and registration, the law does not require a motorist to answer questions. While a driver may want to answer an officer’s questions to expedite the stop, he or she has the right to remain silent. See Berkemer v. McCarty, 468 U.S. 420, 439 (1984). Further, if the officer’s questions are unrelated to the purpose of the stop, prolong it, and are not supported by reasonable suspicion of a crime, they may violate the 4th amendment. Rodriguez v. United States, ___ U.S. ___, 135 S. Ct. 1609 (2015); see also U.S. v. Guijon-Ortiz, 660 F.3d 757 (4th Cir. 2010) (police questioning may exceed the permissible scope of the stop where officer abandons prosecution of traffic stop and embarks on another course of investigation). For example, an officer may not extend a routine traffic stop to ask questions about drug activity.
Generally, Miranda protections don’t apply to questioning of a motorist during a routine traffic stop because the motorist isn’t in custody. Berkemer v. McCarty, 468 U.S. 420, 440 (1984). However, Miranda warnings are required if the officer arrests the driver or takes actions that constitute the functional equivalent of an arrest.
Stoplight RedConsent searches: In the video, after the infraction has been addressed and the traffic stop completed, the officer seeks consent to extend the interaction: “Sir, at this point, you’re free to leave, but what I’d like to do with your permission is just have you step to the rear of your car and just talk with you for a few more minutes.” The driver is agreeable: “OK, sure, that’s no problem.” The officer then asks for permission to pat down the driver’s clothing and search his car.
As the video only depicts consent searches that take place after the stop has ended, there is no discussion of the legal justification that is required to support a frisk of an occupant or search of a car before a stop has ended, or the constitutional limitations on extending a stop and continuing to detain a person once the purpose of the stop has been completed, described in this recent post. See also Jeff Welty, Traffic Stops (2015); 1 North Carolina Defender Manual Ch. 15 (Stops and Warrantless Searches) (2d ed. 2013). In addition, while the narrator states that a motorist has the right to permit or refuse a vehicle search, the action suggests the right thing to do is consent; after all, this is a video demonstrating steps that motorists should follow in order to stay safe, as the narrator indicated at the outset.
As we describe in the manual Raising Issues of Race in North Carolina Criminal Cases (in section 2.7C), consent searches during traffic stops have become increasingly commonplace and officers have broad discretion in deciding who to ask for such consent. Concerns about misuse of this discretion for racial profiling have prompted some states to pass legislation banning the use of consent searches. See The Fourth Amendment and Antidilution: Confronting the Overlooked Function of the Consent Search Doctrine, 119 Harv. L. Rev. 2187, 2187–88 (2006). Questions have been raised about whether motorists actually believe they can decline an officer’s request to consent; some citizens who are confronted with an armed, uniformed officer may feel that submission is compulsory. In North Carolina, to ensure that motorists understand they have the right to decline, some police departments now have a policy that officers must obtain a driver’s signature on a consent form when seeking consent to search. In October 2014, Durham became the second city in the state (following Fayetteville) to adopt a written consent form policy. For data about the impact of this change, see Frank R. Baumgartner, Derek A. Epp, and Kelsey Shoub, Summary of Durham Stops and Searches Before and After Written Consent Policy Reform of October 1, 2014 at p. 4 (2015) (finding that consent searches declined substantially in the first six months after the policy went into effect; however, a corresponding increase occurred in probable cause searches, resulting in no change in search rates during traffic stops overall).
To name the elephant in the reel, the video portrays an African American man being stopped for a minor traffic offense who behaves in a courteous and cooperative manner throughout the encounter. Nonetheless, a backup unit is called, he is asked to get out of his car, he is subjected to a pat down, and he is instructed to sit on the curb with his legs extended and his hands on his knees while his car is searched. Giving the RPD the benefit of the doubt, the action may unfold in this way because the Department wanted to show the range of police actions that may follow a traffic stop. Nonetheless, this dramatization merits a red light to stop and consider the issues, especially in light of data from approximately 13 million North Carolina traffic stops indicating that, compared to White motorists, Black and Latino motorists and passengers are almost twice as likely to be searched following a traffic stop. See Frank R. Baumgartner & Derek Epp, North Carolina Traffic Stop Statistics Analysis: Final Report to the North Carolina Advocates for Justice Task Force on Racial and Ethnic Bias at p. 5 (2012).
Stoplight GreenContacting Internal Affairs: The video ends by encouraging members of the community to contact the RPD Internal Affairs Unit (led by the narrator Captain Bruce) with any complaints about discourteous or inappropriate conduct by officers, and it provides contact information. This is an important public service announcement as many citizens may believe that they have no recourse when an officer fails to follow the law and departmental policies. Results of internal affairs investigations may be discoverable in some cases and may help determine whether a particular officer has selectively enforced the law, e.g., in deciding which motorists to stop or search. See Raising Issues of Race § 2.3D (discussing this issue). I therefore end by giving a green light to the RPD for “taking the Police Department’s integrity and [the Internal Affairs Unit’s] role in helping to preserve it seriously.”

Wednesday, March 9, 2016

Failure to Yield to Pedestrian


www.kisslinglaw.com

Kisslinglaw treats these cases like any other accident and has been able to get them dismissed. According to Fox News,
Pedestrian deaths surged by an estimated 10 percent last year as the economy improved, the price of gas plunged and motorists put more miles behind the wheel than ever before, according to an analysis of preliminary state traffic fatality data.
The growing use of cellphones distracting drivers and walkers may also be partially to blame, states a report released by the Governors Highway Safety Association, which represents governors' highway safety offices. Warmer weather and shorter winters along with a greater awareness of health benefits may also be encouraging people to walk more.
"This is really sobering news," said Richard Retting, co-author of the report. "Pedestrian safety is clearly a growing problem across the country."
The data analyzed were from the first half of 2015. If the trend holds true for the full year, it would be the largest year-to-year increase in pedestrian deaths since 1975 when the current federal system for recording traffic deaths was created.
The report is based on state traffic fatality figures, extrapolated for the full year by researchers at Sam Schwartz Consulting, which specializes in transportation matters.
There were 2,368 pedestrians killed in the first six months of 2015, compared to 2,232 during the same period in 2014 — a six percent increase. Researchers arrived at a 10 percent increase for the entire year by factoring in that fatalities for the first half of the year are typically underreported, and that for at least the last five years an average of 25 percent more pedestrian deaths were recorded in the second half of the year, which includes warmer summer months, Retting said.
Total traffic deaths, which had been trending downward for the past decade, were also up an estimated 8 percent last year. But pedestrian fatalities have been rising since 2005, and now account for 15 percent of total traffic deaths. The last time pedestrian deaths accounted for that large a share of traffic deaths was 25 years ago.
Nearly three-quarters of pedestrian deaths occur after dark, and a third of those killed had been drinking alcohol, according to National Highway Traffic Safety Administration data. By comparison, about 15 percent of motorists involved in those crashes had a blood alcohol content at the legal limit or higher.
Four large population states — California, Florida, Texas and New York — accounted for 42 percent of the pedestrian deaths in the first six months of 2015. States with the highest rate of pedestrian fatalities per 100,000 residents were scattered across the country — Florida, 1.35; Arizona, 1.27; Delaware, 1.27; South Carolina, 1.12; Mississippi, 1.07; Oregon, 1.04, and New Mexico, 1.01. The District of Columbia also tied Oregon for the sixth highest rate, 1.04.
In a related issue, the Amalgamated Transit Union, which represents city bus drivers, estimates that roughly one pedestrian is killed every 10 days by a city bus because of blind spots in poorly designed buses. Wide "A pillars," which connect the windshield to the driver's side window, and poorly placed side mirrors frequently obstruct drivers' view of intersections, according to the union.
"Until the industry demands a change in the design of buses to remove the unnecessary blind spots like European buses, people will continue to die in these preventable accidents," said Larry Hanley, the union's president.

Friday, February 12, 2016

Distracted Driving

Image result for distracted driving
www.kisslinglaw.com

Great article on Distracted Driving and what other states are doing about it as technology changes.  I believe there should be one law.  Pay attention while you are driving.  In addition to texting, it would include reading the paper, eating , putting on your mascara, having a little dog on your lap and yelling at your children.  Thanks to Shea Denning at the NC School of Government for her blog.

Everyone knows that it is unlawful to text while driving in North Carolina.  But what’s the legal status of all of the other distracting things people do with their phones?  Is it unlawful to take a selfie while driving? To post the selfie to Instagram? To look at a friend’s driving selfie on Instagram? To read another friend’s Facebook status update? To search the web for the latest weather forecast?


None of these actions is banned by the state law barring texting while driving. See G.S. 20-137.4A. Some may be prohibited by the statute that bars a person from viewing a computer while driving on the theory that using apps on a mobile phone renders the phone a computer. See G.S. 20-136.1. For the most part, however, the answers to the questions posed above are unclear. As a result, these types of behaviors seldom are addressed by law enforcement officers. Moreover, the fact that many of the hand manipulations that drivers perform on their phones may be lawful makes it harder for law enforcement officers to know when violations of existing state laws occur.
The Virginia plan. Legal ambiguities of this sort are not unique to North Carolina. Yesterday, a legislative panel in Virginia approved a bill aimed at clarifying similar questions under its laws. The Virginia bill amends that state’s existing law banning texting while driving to make it unlawful for a driver to “[m]anually select multiple icons or enter multiple letters or text in [a handheld personal communications device].” (Va. House Bill No. 461 (language added to current Va. Code § 46.2-1078.1 is italicized)). It also eliminates the requirement that the entry of icons or letters be done “as a means of communicating with another person.” The bill further amends existing law by making it unlawful for a driver to “[r]ead any information displayed on the device,” substituting the broader italicized language for “email or text message transmitted to the device or stored within.” Finally, the bill eliminates the exception from the ban for vehicles that are stopped but are not lawfully parked. The bill next will be considered by Virginia’s House Transportation Committee.
The numbers. One proponent of the amendments to Virginia law claimed that “[s]even out of 10 drivers text; 33 percent email; 28 percent browse the internet; 17 percent of people take a selfie; 14 percent post on Instagram and Twitter; 12 percent of people make videos; and 11 percent use Snapchat.” Those percentages are significantly higher than the National Highway Traffic Safety Administration’s report that 2.2 percent of drivers in 2014 text-messaged or visibly manipulated their hand-held devices. NHTSA’s report was based on observation of drivers who stopped at intersections controlled by stop signs or stoplights. The 2.2 percent reported by NHTSA was an increase from 2013, in which it estimated that the percentage of drivers text-messaging or visibly manipulating their phones was 1.7 percent. The rate of such activity was by drivers between ages 16 and 24 was higher: 4.8 percent.
Would broader laws make us safer? Regulating mobile phone use by drivers is a bit like regulating the sweepstakes industry. By the time one activity becomes unlawful, there’s another arguably lawful software application that is more appealing anyway. By way of example, NHTSA reports that drivers’ use of hand-held phones decreased from 6.2 percent in 2005 to 4.3 percent in 2014. While fourteen states ban hand-held phone use by drivers, the vast majority do not. I wonder whether the decrease in this activity has as much to do with hands-free in-vehicle technology and the declining use of phones as, well, phones, as it does with governmental regulation.
Plus, as long as vehicles are driven by humans there will be distractions. I remember my mother constantly filing her fingernails while driving me around as a kid. I’ve seen people driving while reading the newspaper (the old-school kind that is actually printed on a piece of paper). Drivers change radio stations and compact discs. They eat food (sometimes with utensils) while driving. I’m personally acquainted with a person who has applied mascara from behind the wheel. And, as regular blog readers know, I have driven on road trips with actual children in the car. Talk about distracting . . .
Yet there is a sense that the pervasiveness of visual and manual communication by electronic device surpasses these kinds of distractions. (NHTSA reports that 14 percent of all fatal distraction-affected crashes in 2013 involved the use of a mobile phone and 8 percent of all people injured in distraction-affected crashes in 2013 were involved in a crash involving mobile phone use.) The notification of a text message, a like, or a chat calls for immediate attention.  And, for many people, these kinds of alerts arrive every few seconds. To view the notification, the driver must look away from the road. To respond, he or she must look away even longer.
Back to the selfie. Not even the Virginia plan would bar a driver from taking a selfie, distracting as that activity may be. It would, however, bar the driver from posting the selfie on a social media if that action required “select[ing] multiple icons.” If North Carolina decides to get into the selfie-regulation business, I sure hope someone calls me. I want to be in the vanguard of codifying that term.