State v. Jakavis Green - Non-Precedential Opinion

South Carolina Court of Appeals

Filed February 25th, 2026

Detected March 2nd, 2026

Summary

The Court of Appeals of South Carolina affirmed a lower court's decision in State v. Jakavis Green, denying a motion to suppress evidence. The court found that the officer had reasonable suspicion for the traffic stop based on a good-faith understanding of the statute, even if the statute was later challenged as vague.

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What changed

The Court of Appeals of South Carolina issued a non-precedential opinion in State v. Jakavis Green, affirming the trial court's denial of Green's motion to suppress evidence. Green was convicted of habitual traffic offender and driving under suspension (third offense). His appeal argued that the statute used to initiate the traffic stop, S.C. Code § 56-5-2120(b), was unconstitutionally vague, thus lacking reasonable suspicion for the stop. The appellate court held that reasonable suspicion existed based on the officer's good-faith understanding of the statute, citing precedent that a mistaken understanding of a legal prohibition can still support reasonable suspicion, and that the exclusionary rule is intended to deter police misconduct.

This decision means that the convictions and sentences stand. For legal professionals and law enforcement, this case reinforces the principle that a good-faith belief in the validity of a statute, even if later found vague, can justify a traffic stop. It also highlights that the appellate court will review factual findings for evidentiary support and legal conclusions de novo. While this is a non-precedential opinion, it provides guidance on the application of reasonable suspicion standards in traffic stops involving potentially vague statutes within South Carolina.

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Feb. 25, 2026 Get Citation Alerts Download PDF Add Note

State v. Jakavis Green

Court of Appeals of South Carolina

Citations: None known
Docket Number: 2023-000846
Precedential Status: Non-Precedential
Opinion
Authorities (6)
Cited By (0)
Summaries (0)
Similar Cases (0)
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Combined Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE
CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING
EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA
In The Court of Appeals

The State, Respondent,

Jakavis Green, Appellant.

Appellate Case No. 2023-000846

Appeal From Beaufort County
Brooks P. Goldsmith, Circuit Court Judge
Carmen T. Mullen, Circuit Court Judge

Unpublished Opinion No. 2025-UP-384
Submitted November 1, 2025 – Filed November 26, 2025
Withdrawn, Substituted, and Refiled February 25, 2026

AFFIRMED

Appellate Defender Gary Howard Johnson, II, of
Columbia, for Appellant.

Attorney General Alan McCrory Wilson and Senior
Assistant Deputy Attorney General Mark Reynolds
Farthing, both of Columbia; and Solicitor Isaac McDuffie
Stone, III, of Bluffton, all for Respondent.
PER CURIAM: Jakavis Green appeals his convictions for habitual traffic
offender and driving under suspension (third offense) along with his concurrent
sentences of four years' and ninety days' imprisonment, respectively. On appeal,
Green argues the trial court erred by denying his motion to suppress because
section 56-5-2120(b) of the South Carolina Code (2018) is unconstitutionally
vague, and as a result, law enforcement lacked reasonable suspicion to initiate the
traffic stop. We affirm pursuant to Rule 220(b), SCACR, and the following
authorities:

We hold the trial court did not err by denying Green's motion to suppress because
the officer had reasonable suspicion for the traffic stop based on his good-faith
understanding of the statute and the record contains no evidence of police
misconduct that would warrant exclusion. See State v. Frasier, 437 S.C. 625,
633-34, 879 S.E.2d 762, 766 (2022) (explaining appellate courts "review the trial
court's factual findings for any evidentiary support, but the ultimate legal
conclusion—in this case whether reasonable suspicion exists—is a question of law
subject to de novo review"); State v. Butler, 353 S.C. 383, 389, 577 S.E.2d 498,
501 (Ct. App. 2003) ("The stopping of a vehicle and the detention of its occupants
constitutes a seizure and implicates the Fourth Amendment's prohibition against
unreasonable searches and seizures."); State v. Provet, 405 S.C. 101, 108, 747
S.E.2d 453, 457 (2013) (stating violation of a motor vehicle code "provides an
officer reasonable suspicion to initiate a traffic stop"); Heien v. North Carolina,
574 U.S. 54, 60 (2014) ("[R]easonable suspicion can rest on a mistaken
understanding of the scope of a legal prohibition."); Davis v. United States, 564
U.S. 229, 246 (2011) ("[T]he sole purpose of the exclusionary rule is to deter
misconduct by law enforcement."); United States v. Leon, 468 U.S. 897, 918-19
(1984) (stating the exclusionary rule should not be applied "to deter objectively
reasonable law enforcement activity"); State v. German, 439 S.C. 449, 474, 887
S.E.2d 912, 925 (2023) ("Where there is no misconduct and no deterrent purpose
to be served, suppression of the evidence is an unduly harsh sanction." (quoting
State v. Adams, 409 S.C. 641, 653, 763 S.E.2d 341, 348 (2014))). 1

1
This court need not address the constitutionality of section 56-5-2120(b) because
our determinations that the officer had reasonable suspicion for the traffic stop and
that the record contains no evidence of misconduct to warrant exclusion are
dispositive. See Futch v. McAllister Towing of Georgetown, Inc., 335 S.C. 598,
613, 518 S.E.2d 591, 598 (1999) (recognizing an appellate court need not reach the
remaining issues when its determination of a prior issue is dispositive); In re the
Care & Treatment of McCracken, 346 S.C. 87, 92, 551 S.E.2d 235, 238 (2001)
AFFIRMED.2

KONDUROS, GEATHERS, and VINSON, JJ., concur.

(recognizing the supreme court's "firm policy to decline to rule on constitutional
issues unless such a ruling is required").
2
We decide this case without oral argument pursuant to Rule 215, SCACR.