Williamsv.State
James Kemp Williams was stopped at a Bibb County vehicle checkpoint and charged with driving under the influence and violating Georgia’s open-container law. The trial court denied his motion to suppress, and the Court of Appeals affirmed. The Georgia Supreme Court reversed after applying the checkpoint framework it announced in Brown v. State. The Court accepted the finding that the particular checkpoint was authorized in advance by a supervisor rather than created spontaneously by a field officer. But the State failed to prove that the Bibb County Sheriff’s Office checkpoint program had an appropriate primary purpose other than the general interest in crime control. The office’s written policy authorized roadblocks for “legitimate law enforcement purposes,” while the evidence showed that a field supervisor had broad discretion to conduct multiple checkpoints each week without prior authorization, written documentation, or meaningful limits on time and location. Edmond requires the primary-purpose inquiry to be made at the programmatic level; a proper purpose for one checkpoint cannot cure an inadequately defined agency program. Because the State failed to satisfy that independent Fourth Amendment requirement, Williams’s stop was unconstitutional. The Court reversed the denial of suppression.
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