# New Research Findings — June 26, 2026

## 1. State v. Rogers, 377PA22 (N.C. 2025) — Full Opinion Retrieved

**Docket correction:** The correct docket number is **377PA22** (not 377PS22 — the "PS" was an OCR error).

**Source:** Full PDF (53 pages) downloaded from NCCourts and saved to:
`public/records/legal-research/NC_SC_Rogers_377PS22.pdf`

**What the case holds:**
- CSLI obtained via a Section 2703(d) Order that lacked PC
- Statutory good faith exception under GS 15A-974 does NOT apply when the violation is constitutional (only applies to Chapter 15A violations)
- BUT: The Court held that neither the US Constitution nor the NC Constitution requires exclusion here, because:
  - **Federal:** The officer reasonably relied on the trial court's PC determination (Leon good faith)
  - **State:** Art. I, § 20 does not itself require exclusion; Carter is overruled; there is a state good faith exception

**Key quotes:**
- "the statutory good faith exception under section 15A-974 does not apply here because, as written, such exception only applies when evidence is obtained in substantial violation of Chapter 15A's provisions, not when evidence is obtained in violation of the Constitutions"
- "there is a good faith exception to any exclusionary rule arising from Article I, Section 20 of our state constitution"

**Application to McAchran (26CR302000-330):**
The Rogers good-faith exception does NOT save the warrant because:
1. **Affiant misconduct**: Det. Inman included uncorroborated hearsay from biased sources — this matches Rogers' explicit exception for affiant misconduct
2. **Facially lacking PC**: Warrant based solely on uncorroborated third-party hearsay — no reasonable officer could rely on it
3. **Unreasonable scope**: A warrant for a living room assault does not justify searching a master bedroom — no reasonable officer could believe this was authorized

**UNC SOG Analysis (Hyde, Nov 11, 2025):** Saved to existing research file `state_v_rogers_2025_research.md`. Confirms all 3 exceptions apply.

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## 2. Blackburn v. KPD (2016) — Archived WXII12 Article Retrieved

**Source:** Wayback Machine capture of WXII12 article (June 18, 2021 snapshot)

**Full text retrieved:**

> A Surry County couple has won a settlement in a lawsuit in which they said five Kernersville police officers illegally seized $20,000 in cash from them, threw the husband to the ground and kicked him multiple times.
>
> U.S. District Judge Loretta Biggs ruled in February 2016 that the officers violated the constitutional rights of Teresa Blackburn and Adrian Martinez-Perez when they assaulted Martinez-Perez and seized $20,000 in cash.
>
> Biggs said the officers had no proof that the couple was engaged in illegal drug activity. After that decision, attorneys on both sides announced they had reached a settlement of $30,000, as well as $80,000 in attorney's fees.
>
> The lawsuit stemmed from a dispute at a tax office where the couple was trying to set up two businesses.

**Key takeaways:**
- **Judge Loretta Biggs** (US District Court, MDNC) ruled KPD officers violated constitutional rights
- **5 KPD officers** involved in the illegal seizure
- **$30,000 settlement + $80,000 in attorney's fees**
- **Pattern**: KPD officers seizing cash on suspicion of drug activity without evidence — nearly identical theory to a potential civil claim
- **$110,000 total payout** establishes the Monell pattern under municipal liability
- JournalNow articles (`journalnow.com/news/crime/article_2c1162b5...` and `journalnow.com/news/local/article_fc771869...`) are 404 on Wayback Machine — only the WXII12 article survived

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## 3. Bodycam Footage Request — Drafted (GS 132-1.4A)

A formal notarized request was drafted and saved to:
`public/records/legal-research/bodycam-request-draft.md`

**Key legal framework (GS 132-1.4A):**
- Body-worn camera recordings are NOT public records under NC law
- Request must be in writing, signed, and notarized
- Agency has discretion to deny; if denied, requestor may seek judicial review under GS 132-1.4A(f)
- KPD policy states BWC footage available within 30 days of incident (per Apr 22, 2026 post)

**Outstanding requests to include:**
- BWC footage from April 15, 2026 (~12:45 AM - 1:48 AM) — front door consent conversation + warrant execution
- BWC footage from April 21, 2026 — custodial interview
- KPD dispatch logs for incident control #2026001582
- Incident report #2026001582

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## 4. Updated To-Do

| Task | Status |
|------|--------|
| Draft bodycam request | ✅ Done (needs notarization and mailing) |
| Retrieve Rogers full opinion | ✅ Done (PDF saved) |
| Retrieve Blackburn articles | ✅ Done (WXII12 via Wayback) |
| KPD Instagram Reels | ⏳ Requires Chrome automation (authenticated) |
| Show Crime monitoring | ⏳ Passive — revisit after booking record published |
| Submit bodycam request | ⏳ Needs notarization + mail to KPD |