Douglas Wayne Brown was stopped at a Cobb County traffic-safety checkpoint and later charged with driving under the influence, drug offenses, obstruction, and attempting to remove a weapon from an officer. The trial court suppressed his statements and other evidence, finding that the sergeant implemented the checkpoint as a field officer rather than deciding in advance as a supervisor and that the checkpoint was inadequately staffed. The Court of Appeals reversed after applying de novo review. The Georgia Supreme Court reversed the appellate judgment and reinstated suppression. It held that a checkpoint must satisfy two distinct Fourth Amendment safeguards: its program must have an appropriate primary purpose other than general crime control, and the particular checkpoint must be implemented in advance by supervisory personnel rather than an officer acting in the field. The State failed to prove the second requirement because testimony about when the checkpoint was planned was disputed, undocumented, and reasonably subject to the trial court’s credibility determination. The Court rejected understaffing as an independent constitutional violation, while recognizing that staffing could bear on whether the checkpoint was lawfully planned and operated. The judgment was reversed, and the trial court’s suppression ruling stood.