E.D.N.C.: DL checkpoint stopping all cars was reasonable

Defendant was stopped at a driver’s license checkpoint where all cars were stopped. The court finds the checkpoint constitutional. Defendant then consented to the search of his car. United States v. Moore, 2017 U.S. Dist. LEXIS 116012 (E.D. N.C. May 18, 2017), adopted, 2017 U.S. Dist. LEXIS 115453 (E.D.N.C. July 25, 2017).

The officer had reasonable suspicion to detain defendant during the traffic stop that defendant was trafficking drugs when defendant appeared overly nervous, the vehicle belonged to an absent third party, defendant said he was returning from Philadelphia, a source location for narcotics, a records check showed a lengthy criminal history for assault and drug offenses, and the officer remembered prior contact with defendant and with the same vehicle that had yielded drugs and a hypodermic needle. That reasonable suspicion permitted bringing a drug dog to the scene. Commonwealth v. Green, 2017 PA Super 244, 2017 Pa. Super. LEXIS 571 (July 25, 2017).*