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Illinois v. Caballes

Supreme Court of the United States

November 10, 2004, Argued ; January 24, 2005, Decided

No. 03-923

Case Summary

Procedural Posture

A state trooper stopped respondent for speeding. A second trooper drove to the scene with his dog and walked the dog around respondent's car while the first trooper wrote a warning ticket. When the dog alerted at respondent's trunk, the officers searched the trunk and found marijuana. Respondent's motion to suppress was denied at his drug trial. The Illinois Supreme Court reversed. Petitioner State's petition for a writ of certiorari was granted.

Overview

The U.S. Supreme Court granted certiorari on the question of whether the Fourth Amendment required reasonable, articulable suspicion to justify using a drug-detection dog to sniff a vehicle during a legitimate traffic stop. The state trial court concluded that the duration of the stop was entirely justified by the traffic offense and the ordinary inquiries incident to such a stop. The state supreme court concluded that because the canine sniff was performed without any specific and articulable facts to suggest drug activity, the use of the dog unjustifiably enlarged the scope of a routine traffic stop into a drug investigation. The U.S. Supreme Court held that the use of a well-trained narcotics-detection dog--one that did not expose noncontraband items that otherwise would have remained hidden from public view--during a lawful traffic stop, generally did not implicate legitimate privacy interests. The dog sniff was performed on the exterior of respondent's car while he was lawfully seized for a traffic violation. Any intrusion on respondent's privacy expectations did not rise to the level of a constitutionally cognizable infringement.

Outcome

The judgment was vacated, and the case was remanded for further proceedings.

LexisNexis® Headnotes

 

 

Constitutional Law > ... > Fundamental Rights > Search & Seizure > Probable Cause

Constitutional Law > ... > Fundamental Rights > Search & Seizure > Scope of Protection

Criminal Law & Procedure > Search & Seizure > Seizure of Persons

HN1  Probable Cause

A seizure that is lawful at its inception can violate the Fourth Amendment if its manner of execution unreasonably infringes interests protected by the United States Constitution. A seizure that is justified solely by the interest in issuing a warning ticket to a driver can become unlawful if it is prolonged beyond the time reasonably required to complete that mission.

 

Criminal Law & Procedure > Search & Seizure > Expectation of Privacy

Constitutional Law > ... > Fundamental Rights > Search & Seizure > Scope of Protection

HN2  Expectation of Privacy

Official conduct that does not compromise any legitimate interest in privacy is not a search subject to the Fourth Amendment. The United States Supreme Court holds that any interest in possessing contraband cannot be deemed "legitimate," and thus, governmental conduct that only reveals the possession of contraband compromises no legitimate privacy interest. This is because the expectation that certain facts will not come to the attention of the authorities is not the same as an interest in privacy that society is prepared to consider reasonable.

 

Criminal Law & Procedure > Search & Seizure > Warrantless Searches > Dog Sniff Searches

Constitutional Law > ... > Fundamental Rights > Search & Seizure > Scope of Protection

HN3  Dog Sniff Searches

The United States Supreme Court treats a canine sniff by a well-trained narcotics-detection dog as "sui generis" because it discloses only the presence or absence of narcotics, a contraband item.

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543 U.S. 405 ; 125 S. Ct. 834 ; 160 L. Ed. 2d 842 ; 2005 U.S. LEXIS 769 ; 73 U.S.L.W. 4111; 18 Fla. L. Weekly Fed. S 100

ILLINOIS, Petitioner v. ROY I. CABALLES

Prior History:  [1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF ILLINOIS.

People v. Caballes, 207 Ill. 2d 504, 802 N.E.2d 202, 2003 Ill. LEXIS 2280, 280 Ill. Dec. 277 (2003)

Disposition: Vacated and remanded.