Handcuffing a Flight Risk Suspects In North Carolina

In State v. Campbell, N.C. App, 656 S.E.2d 721, 727 (2008), the Supreme Court of North Carolina held that police officers acted reasonably under Hensley by handcuffing a defendant they deemed to be a flight risk, and that the officers' actions did not convert the stop into an arrest. "The permissible scope of a Terry stop has expanded in the past few decades, allowing police officers to neutralize dangerous suspects during an investigative detention using measures of force such as placing handcuffs on suspects, placing the suspect in the back of police cruisers, drawing weapons, and other forms of force typically used during an arrest." Campbell, N.C. App. at, 656 S.E.2d at 727.