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Williams v. State

Police had reasonable suspicion to stop the defendant's vehicle when an officer saw him commit two crimes—failure to obey an officer directing traffic to stop at a roadblock and failure to drive with due care.

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A jury found Joseph Williams guilty of three misdemeanors related to his refusal to cooperate with police at a roadblock. Williams appeals, arguing that the trial court erred by denying his motion to suppress because the roadblock was unconstitutional. We conclude that the police had reasonable suspicion to stop Williams independently from the roadblock, and we therefore affirm.

Viewed in a light favorable to the verdict,1 the record shows that on the evening of January 3, 2014, officers from the Atlanta Police Department set up a safety checkpoint at an intersection in a residential neighborhood. The officers flagged down all vehicles passing through the intersection to check drivers’ licenses and vehicle registrations. Two officers stood on the north side of the intersection motioning for southbound motorists to halt just before a stop sign, while a third officer stood on the south side of the intersection intercepting northbound motorists. Williams approached the intersection traveling southbound and failed to heed the commands of the two officers there to stop. He proceeded to the stop sign, stopped there, and then continued through the intersection.

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