State v. Campola
812 S.E.2d 681, 258 N.C. App. 292 (2018)
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Rule of Law:
An officer may prolong a traffic stop to investigate suspected criminal activity without violating the Fourth Amendment if reasonable suspicion of that activity develops while the officer is diligently pursuing the original mission of the stop.
Facts:
- Officer Matthew Freeman, while on patrol in a high-crime area, observed Matthew Matchin and Samuel Campola (Defendant) in a car in a Motel 6 parking lot.
- Upon seeing Officer Freeman, Matchin and Campola appeared surprised and quickly drove out of the parking lot at a high rate of speed.
- Officer Freeman followed the vehicle and observed it make an illegal right turn without yielding, nearly causing a collision.
- Officer Freeman initiated a traffic stop. During the stop, the driver, Matchin, appeared unusually nervous.
- While running their information, Officer Freeman discovered that both Matchin and Campola had multiple prior drug arrests.
- After a backup officer, Officer Weston, arrived, he approached the passenger side of the vehicle and observed a syringe cap on the driver's seat.
- When Officer Weston asked Campola to step out of the vehicle, he observed a second syringe cap in the passenger's seat.
- A subsequent search of the vehicle revealed two syringes, a spoon with a brown substance, and other paraphernalia.
Procedural Posture:
- Samuel Campola (Defendant) was indicted for possession of heroin and possession of drug paraphernalia.
- In the trial court, Campola filed a pre-trial motion to suppress evidence, arguing the traffic stop was unconstitutionally extended.
- Following a hearing, the trial court denied the motion to suppress.
- At trial, a jury found Campola guilty on both charges, and the court entered judgment.
- Campola (appellant) appealed the trial court's judgment to the Court of Appeals of North Carolina.
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Issue:
Does a police officer violate the Fourth Amendment by prolonging a traffic stop to investigate suspected drug activity when reasonable suspicion for that activity develops while the officer is diligently pursuing the original mission of the stop, such as running database checks?
Opinions:
Majority - Inman, Judge.
No. An officer does not unconstitutionally prolong a traffic stop when reasonable suspicion of a separate crime arises before the original mission of the stop is completed. The court reasoned that the 'mission' of a traffic stop includes ordinary inquiries like checking licenses, registration, warrants, and criminal histories for officer safety. Here, Officer Freeman was still engaged in these permissible tasks when he developed reasonable suspicion of drug activity. The totality of the circumstances—including the occupants' presence in a high-crime area, their evasive driving after seeing the officer, the driver's nervousness, and their prior drug arrests—was sufficient to justify extending the stop for further investigation before the traffic-related mission was finished.
Analysis:
This case clarifies the application of the Supreme Court's ruling in Rodriguez v. United States, which limits the duration of traffic stops. The court's analysis confirms that officer safety measures, such as waiting for backup and conducting criminal history checks, are part of the stop's permissible duration and do not constitute an improper extension. The decision establishes that reasonable suspicion can be formed from a collection of facts gathered during these routine procedures, lawfully transforming a simple traffic stop into a broader criminal investigation. This provides a clear framework for how facts developed during the initial, lawful phase of a stop can justify its prolongation for investigating other potential crimes.
