suppression hearings North Carolina

The Supreme Court of North Carolina’s opinion in North Carolina v. Rogers (Oct. 17, 2025) deserves careful study by criminal defense and DUI defense lawyers.

TL;DR Quick Take North Carolina v. Rogers reshapes how certain suppression motions may be litigated in North Carolina. The Supreme Court interpreted the 2011 “good faith” amendment to N.C.G.S. §15A-974 as significantly limiting the scope of the exclusionary rule, allowing evidence obtained through unlawful searches to be admitted if officers relied on objectively reasonable belief in the legality of their conduct. The decision narrows the path for defendants seeking suppression and marks a turning point in how trial courts evaluate Fourth Amendment violations.

Editor’s Note: The Supreme Court’s decision in State v. Rogers addressed good-faith reliance on a judicial order, not warrantless arrests or searches. The opinion leaves open whether the same reasoning will apply to warrantless seizures or probable-cause challenges. For now, Rogers appears to narrow the exclusionary rule only in the context of judicially authorized warrants and orders.

The exclusionary rule is a foundational principle in American criminal law. While it traces its origins to federal constitutional doctrine, it now plays a central role in everyday trial practice, including in state courtrooms across North Carolina. The rule is most often encountered through motions to suppress evidence, but its reach extends further, sometimes forming the basis for a motion to dismiss when the taint of unlawful police conduct affects more than a single piece of evidence. To understand why the rule exists and how it functions, it helps to examine both its historical roots and its practical application today.

Though courts often describe the exclusionary rule as a remedy, its function is broader than that. It reflects an institutional decision to draw a line between the conduct of law enforcement and the integrity of the courts. It limits what the State may use to prosecute someone when a constitutional violation has occurred. And while it can lead to the suppression of important or even decisive evidence, the logic behind the rule rests on the idea that constitutional limits on police conduct are only meaningful if they carry enforceable consequences.

Articles Tagged with suppression hearings North Carolina

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