State v. Benthall

CourtCourt of Appeals of North Carolina
DecidedApril 15, 2026
Docket25-781
StatusUnpublished
AuthorJudge Allegra Collins

This text of State v. Benthall (State v. Benthall) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Benthall, (N.C. Ct. App. 2026).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-781

Filed 15 April 2026

Guilford County, Nos. 23CR028456-400, 23CR399568-400, 23CR399571-400

STATE OF NORTH CAROLINA

v.

PAUL BENTHALL, III

Appeal by Defendant from order entered 20 February 2025 and judgments

entered 26 February 2025 by Judge William A. Wood, II, in Guilford County Superior

Court. Heard in the Court of Appeals 24 March 2026.

Attorney General Jeff Jackson, by Special Deputy Attorney General Alex R. Williams, for the State-Appellee.

Appellate Defender Glenn Gerding, by Assistant Appellate Defender James R. Grant, for Defendant-Appellant.

COLLINS, Judge.

Defendant Paul Benthall appeals from an order denying his motion to suppress

and judgments entered upon a jury’s guilty verdicts of possession of a firearm by a

felon and possession of cocaine, and Defendant’s guilty plea to attaining habitual

felon status. Defendant argues that the trial court erred by denying his motion to STATE V. BENTHALL

Opinion of the Court

suppress, and that the charge of possession of a firearm by a felon under N.C. Gen.

Stat § 14-415.1 is unconstitutional both facially and as applied. Because competent

evidence supports the trial court’s findings of fact and those findings support its

conclusion that the officer had reasonable suspicion to believe Defendant had violated

N.C. Gen. Stat. § 20‑154(a), we affirm the denial of the motion to suppress. Defendant

has failed to preserve his constitutional argument for appellate review, and that

portion of his appeal is dismissed.

I. Background

Defendant was indicted for various crimes as a result of items found during a

search of his car. Prior to trial, Defendant moved to suppress all evidence seized as

a result of the search, arguing that law enforcement’s stop of his car was not

supported by reasonable suspicion. A suppression hearing was held where Sergeant

J.L. Matthews was the sole witness. The evidence presented at the suppression

hearing tended to show the following:

Matthews was conducting surveillance at the Cavalier Inn, an area he

described as a “high‑frequency narcotics location[.]” After seeing what he believed

was a hand‑to‑hand drug transaction, Matthews began following Defendant’s car. He

did not stop Defendant based on the suspected transaction; instead, he continued

following him to determine whether Defendant would commit a traffic violation,

which would justify a stop.

After following Defendant for approximately six miles, Matthews saw him

-2- STATE V. BENTHALL

change lanes twice on Yanceyville Street, a street with two lanes of traffic in each

direction, without signaling. At the time, Matthews was “[n]o more than 30 to 50

yards” or “seven to ten car lengths” behind Defendant in one northbound lane;

another officer, Detective Pacific, was in the adjacent northbound lane. Matthews

testified that “multiple other vehicles” were traveling northbound, though he could

not recall their specific locations. He further testified Defendant’s unsignaled lane

changes “potentially could have affected multiple other cars on the road.” Matthews

initiated a traffic stop for allegedly failing to use a traffic signal, in violation of N.C.

Gen. Stat. § 20-154(a).

The trial court found Matthews credible; found Defendant had made two

unsignaled lane changes while other vehicles, including two police vehicles, were

traveling behind him in the same direction; and concluded Defendant had a duty to

signal under section 20‑154(a). The trial court thus concluded Matthews had

reasonable suspicion to initiate the traffic stop and denied the motion to suppress.

The jury convicted Defendant of possession of a firearm by a felon and simple

possession of cocaine and acquitted Defendant on all other charges. Defendant then

pled guilty to having attained habitual felon status. Defendant timely appealed.

II. Discussion

A. Motion to Suppress

Defendant argues that the trial court erred by denying his motion to suppress

because the evidence and the trial court’s findings fail to support a conclusion that

-3- STATE V. BENTHALL

Matthews had a reasonable suspicion that Defendant had failed to use a traffic signal,

in violation of N.C. Gen. Stat. § 20-154(a).

“When reviewing a ruling on a motion to suppress, we analyze whether the

trial court’s underlying findings of fact are supported by competent evidence and

whether those factual findings in turn support the trial court’s ultimate conclusions

of law.” State v. Johnson, 370 N.C. 32, 35 (2017) (cleaned up). Conclusions of law are

reviewed de novo. State v. Watkins, 220 N.C. App. 384, 388 (2012).

Traffic stops are reviewed under the reasonable suspicion standard which

requires that “[t]he stop . . . be based on specific and articulable facts, as well as the

rational inferences from those facts, as viewed through the eyes of a reasonable,

cautious officer, guided by his experience and training.” State v. Watkins, 337 N.C.

437, 441 (1994) (citing Terry v. Ohio, 392 U.S. 1, 21-22 (1968)). The reasonable

suspicion standard need only be “satisfied by some minimal level of objective

justification” for the stop. State v. Styles, 362 N.C. 412, 414 (2008) (quotation marks

and citation omitted).

Under N.C. Gen. Stat. § 20‑154(a), a driver must signal a turn or lane change

when “the operation of any other vehicle may be affected by such movement.” N.C.

Gen. Stat. § 20‑154(a) (2025). The duty to signal arises when another vehicle may be

affected–not only when another vehicle is actually affected. See Styles, 362 N.C. at

416-17.

In Styles, the defendant’s failure to signal a lane change “immediately in front

-4- STATE V. BENTHALL

of” a patrol car provided reasonable suspicion of a section 20‑154(a) violation because

such a movement “may affect” the trailing vehicle. Id. Similarly, in State v. McRae,

the officer had reasonable suspicion to stop the defendant based on his failure to use

his turn signal. 203 N.C. App. 319, 323 (2010). There “defendant was traveling,

before his turn, in a through lane with ‘medium’ traffic and was a short distance in

front of the police officer.” Id. We held “[t]he trial court did not err in concluding that

a reasonable officer would have believed, under these circumstances, that the failure

to use a turn signal could have affected another motor vehicle.” Id.

Although Defendant here was not “immediately” in front of Matthews, the trial

court found, and the record supports, that Defendant was seven to ten car lengths in

front of Matthews–close enough for Matthews to clearly observe the lane changes;

Defendant was traveling ahead of two police vehicles, both of which were in the same

direction of travel; other vehicles were also traveling northbound; and Defendant

executed two lane changes without signaling. The trial court was entitled to credit

Matthew’s testimony that Defendant’s lane changes “potentially could have affected

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Related

Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
State v. Styles
665 S.E.2d 438 (Supreme Court of North Carolina, 2008)
State v. Ivey
633 S.E.2d 459 (Supreme Court of North Carolina, 2006)
State v. Lloyd
552 S.E.2d 596 (Supreme Court of North Carolina, 2001)
State v. McRae
691 S.E.2d 56 (Court of Appeals of North Carolina, 2010)
State v. Watkins
446 S.E.2d 67 (Supreme Court of North Carolina, 1994)
State v. Watkins
725 S.E.2d 400 (Court of Appeals of North Carolina, 2012)
State v. Johnson
803 S.E.2d 137 (Supreme Court of North Carolina, 2017)

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Bluebook (online)
State v. Benthall, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-benthall-ncctapp-2026.