NC: Consent sought while officer holding DL wasn’t voluntary because here it was an unlawful seizure

“Defendant’s main argument appears to be that when Officer Sletten failed to return defendant’s identification after finding no outstanding warrants and after the initial reason for the detention was satisfied, he instead requested defendant’s consent to search, the seizure was unlawful, and defendant’s consent was not voluntarily given. We agree.” State v. Parker, 2017 N.C. App. LEXIS 940 (Nov. 7, 2017).

The lack of meaningful findings of the trial court preclude appellate review of defendant’s motoin to suppress. Remanded. State v. Faulk, 2017 N.C. App. LEXIS 941 (Nov. 7, 2017).*

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