Law School Case Brief
City of Indianapolis v. Edmond - 531 U.S. 32, 121 S. Ct. 447 (2000)
If the primary purpose of a narcotics checkpoints is in the end to advance "the general interest in crime control," then the usual requirement of individualized suspicion where the police seek to employ a checkpoint primarily for the ordinary enterprise of investigating crimes is not suspended. The Supreme Court of the United States has declined to sanction stops justified only by the generalized and ever-present possibility that interrogation and inspection may reveal that any given motorist has committed some crime. In other words, the Court has declined to approve a program whose primary purpose is ultimately indistinguishable from the general interest in crime control.
Petitioner City of Indianapolis operated a checkpoint program under which the police, acting without individualized suspicion, stopped a predetermined number of vehicles at roadblocks in various locations on city roads for the primary purpose of the discovery and interdiction of illegal narcotics. Under the program, at least one officer would approach each vehicle, advise the driver that he or she was being stopped briefly at a drug checkpoint, ask the driver to produce a driver's license and the vehicle's registration, look for signs of impairment, and conduct an open-view examination of the vehicle from the outside. In addition, a narcotics-detection dog would walk around the outside of each stopped vehicle. Respondents James Edmond and Joell Palmer ("motorists") who had been stopped at such a checkpoint filed suit in the United States District Court for the Southern District of Indiana on behalf of themselves and a class of all motorists who had been stopped or were subject to being stopped in the future at the City's checkpoints. One of the claims asserted that the checkpoint program violated the Federal Constitution's Fourth Amendment. The district court, in denying the motorists' motion for a preliminary injunction, concluded that the program did not violate the Fourth Amendment. The United States Court of Appeals for the Seventh Circuit reversed on the grounds that the program was meant to intercept a completely random sample of drivers. Moreover, the appellate court held that there was neither probable cause nor articulable suspicion to stop any given driver, and that the program did not fit any of the exceptions allowed under the Fourth Amendment. The Supreme Court of the United States granted the City's petition for certiorari.
Did the City's checkpoint program violate the Fourth Amendment?
The Supreme Court of the United States affirmed the determination that the checkpoints violated the Fourth Amendment because the primary purpose of the narcotics checkpoint program was to uncover evidence of ordinary criminal wrongdoing. According to the Court, because the authorities pursued primarily general crime control purposes at the checkpoints, the stops could only be justified by some quantum of individualized suspicion.
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