South Carolina v. Alston

Stepheno Alston was tried in absentia and convicted by a jury of trafficking in cocaine. The trial judge sentenced Alston to twenty-five years' imprisonment. On appeal, the Court of Appeals affirmed Alston's conviction and sentence, upholding the trial judge's denial of Alston's motion to suppress evidence found in his vehicle following a traffic stop. Specifically, the Court of Appeals agreed with the trial judge that: (1) the arresting officer had (a) probable cause to stop Alston's vehicle for a violation of South Carolina's failure to maintain a lane statute and (b) reasonable suspicion to support a brief investigatory detention; (2) the officer had reasonable suspicion that illegal activity was occurring to justify extending the duration of the traffic stop; and (3) Alston voluntarily gave his consent to the officer to search his vehicle. The South Carolina Supreme Court granted Alston's petition for a writ of certiorari to review the decision of the Court of Appeals. Based on South Carolina rules of statutory construction, the Supreme Court held the offense of failure to maintain a lane was not a strict liability offense. As a result, an officer must consider all relevant circumstances in deciding whether to stop a vehicle for a violation of this statute. Applying this interpretation to the facts of the instant case, we conclude there is evidence to support the trial judge's finding that the initial traffic stop was valid. Further, the Court found evidence to support the trial judge's determination that the arresting officer had reasonable suspicion of criminal activity to extend the scope of the stop beyond its initial purpose and that Alston voluntarily consented to the warrantless search. Therefore, while the Supreme Court agreed with the result reached by the Court of Appeals, it modified its analysis regarding the interpretation of section 56-5-1900 and the basis for which the officer had reasonable suspicion to extend the duration of the traffic stop. Accordingly, the decision of the Court of Appeals was affirmed as modified. View "South Carolina v. Alston" on Justia Law