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City of Indianapolis v. Edmond:

US Supreme Court, 2000 (O’Connor)

Author: P.V. Neff

 

  1. F: In 8/98 the city began operating vehicle checkpoints to interdict narcotics. There were 6 such roadblocks, stopping a total of 1,161 vehicles and arresting 104 motorists in about 4 months—58 for drug related crimes (hit rate of 9%--very high compared the hit rate in Sitz/Martinez-Fuerte cases).
    1. Procedure at stop:

                                                               i.      Officers had predetermined system for setting up checkpoints and choosing what vehicles were pulled over—no discretion.

                                                             ii.      Max time for initial stop w/o suspicion was 5min, average stop was 2-3 minutes.

                                                            iii.      Inspection was visual walk-around and brief questioning of driver. Dogs walked around vehicle.

                                                           iv.      A search could only be done w/consent or particularized suspicion

  1. I: Were the roadblocks Constitutional?
  2. P: District court denied motion for prelim injunction, 7th Cir. Reversed, US Supreme Court affirms.
  3. H/R:
    1. Obviously there’s a seizure, but the fact that the dogs are used does not create a search of the initial stop.
    2. Boarder/DUI Checks Distinguished:

                                                               i.      In the other checkpoint cases the Court allowed them b/c they were designed primarily to serve purposes closely related to the problems of policing the boarder or the necessity of ensuring roadway safety. Because the primary purpose of the Indianapo0lis checkpoint program is…ordinary criminal wrongdoing, the program contravenes the 4th Amendment.

                                                             ii.      Petitioners argue their stop serves the same general purpose—crime prevention, but this is too broad.

                                                            iii.      They also argue that drugs are an especially severe problem, but the gravity of the problem alone cannot be dispositive.

1.      Should consider the nature of the interests threatened and their connection to the particular4 law enforcement practices at issue.

                                                           iv.      Unlike Sitz, these checkpoints did not serve a purpose specifically aimed at highway safety—too indirect an impact.

    1. We cannot sanction stops justified only by the generalized interest and ever-present possibility that interrogation and inspection may reveal that any given motorist has committed some crime.
    2. Whren’s holding that the subjective intent of the officers does not matter does not apply b/c it was specifically addressing ordinary, PC 4th analysis—this  is not a PC situation.
    3. This holding applies to programs, not the motivation of particular officers. If there is a Constitution reason for a checkpoint, arrests for narcotics found as a secondary purpose are fine.
  1. Dissent:
    1. These stops serve the legitimate interests in preventing drunk driving and checking licenses and registration. The primary purpose of the stop should not be controlling.
    2. The reasonableness of the checkpoints turns on whether they effectively serve a significant state interest w/minimal intrusion on motorists.
    3. The Court has created a new test, the primary purpose test, which is ill suited to brief roadblock seizures.
    4. Thomas: Sitz and Martizes were wrongly decided, this whole system is flawed.