Smith's Criminal Case Compendium
Table of Contents
State v. Fields, 219 N.C. App. 385 (Mar. 6, 2012)
An officer had reasonable suspicion to stop the defendant’s vehicle where the defendant’s weaving in his own lane was sufficiently frequent and erratic to prompt evasive maneuvers from other drivers. Distinguishing cases holding that weaving within a lane, standing alone, is insufficient to support a stop, the court noted that here “the trial court did not find only that defendant was weaving in his lane, but rather that defendant's driving was 'like a ball bouncing in a small room'” and that “[t]he driving was so erratic that the officer observed other drivers -- in heavy traffic -- taking evasive maneuvers to avoid defendant's car.” The court determined that none of the other cases involved the level of erratic driving and potential danger to other drivers that was involved in this case.