State v. Alston, 422 S.C. 270

Summary

The South Carolina Supreme Court reviewed the denial of Stepheno Jemain Alston's motion to suppress cocaine discovered during a vehicle search following a traffic stop. The court held that the officer had probable cause to stop the vehicle based on repeated weaving and lane-line strikes, and that the circumstances supported continued detention and consent to search. The court affirmed the Court of Appeals' decision as modified.

Holdings

1. Section 56-5-1900 creates two separate offenses and is not a strict-liability statute because the phrase "as nearly as practicable" requires consideration of the circumstances surrounding the vehicle's lane deviations.
2. The officer had probable cause to stop Alston because he observed the vehicle repeatedly drift within its lane and strike the lane-dividing lines, conduct that could constitute a violation of section 56-5-1900 and warranted investigation of possible impairment.
3. The officer's questioning exceeded the purpose of the initial traffic stop, but the continued detention was lawful because the totality of the circumstances, together with the officer's experience and training, supported an objectively reasonable and articulable suspicion that criminal activity was occurring.
4. The warrantless search was reasonable because the record contained evidence supporting the trial judge's finding that Alston voluntarily consented to the search.

Questions Presented

1. Whether repeated drifting within a lane and striking lane-dividing lines violated S.C. Code section 56-5-1900 sufficiently to establish probable cause for the traffic stop.
2. Whether the officer had objectively reasonable and articulable suspicion of criminal activity to extend the detention after the traffic-stop tasks were completed.
3. Whether Alston voluntarily consented to the warrantless search of the vehicle.
4. Whether section 56-5-1900 creates a strict-liability offense.

Disposition

affirmed