Jonesv.State
During a Georgia State Patrol roadblock, a trooper saw Michael Jeffery Jones turn his truck into a shopping-center parking lot. The trooper blocked the lot’s exit with his patrol car, activated his lights, and told Jones to remain while he investigated why Jones had turned. The trooper then smelled alcohol and marijuana, administered field-sobriety tests, and arrested Jones for driving under the influence. The trial court treated the encounter as consensual and denied Jones’s motion to suppress; the Court of Appeals affirmed. The Supreme Court of Georgia reversed. It held that the trooper’s deliberate blocking of the only exit and instruction that Jones remain restrained Jones’s freedom of movement, so the encounter was a Fourth Amendment seizure rather than a consensual police-citizen conversation. Because the trooper identified no specific, articulable facts suggesting that Jones had violated a law or made an evasive maneuver, he lacked reasonable suspicion for the traffic stop. The court concluded that evidence obtained from the unconstitutional stop should have been suppressed and reversed the judgment. Jones’s remaining subpoena-related claim was moot.
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