Law School Case Brief
Delaware v. Prouse - 440 U.S. 648, 99 S. Ct. 1391 (1979)
Except in those situations in which there is at least articulable and reasonable suspicion that a motorist is unlicensed or that an automobile is not registered, or that either the vehicle or an occupant is otherwise subject to seizure for violation of law, stopping an automobile and detaining the driver in order to check his driver's license and the registration of the automobile are unreasonable under the U.S. Const. amend. IV. A state is not precluded from developing methods for spot checks that involve less intrusion or that do not involve the unconstrained exercise of discretion. Persons in automobiles on public roadways may not for that reason alone have their travel and privacy interfered with at the unbridled discretion of police officers.
A New Castle County, Delaware, police officer stopped an automobile and seized marijuana in plain view on the car floor after smelling marijuana smoke as he walked toward the stopped vehicle. An occupant of the vehicle who had been indicted for illegal possession of a controlled substance moved to suppress, at his state trial, the marijuana seized as a result of the stop. At a hearing on the motion to suppress, the police officer testified that prior to stopping the vehicle, no traffic or equipment violations nor any suspicious activity had occurred. In fact, the police officer only made the stop in order to check the driver's license and the registration of the vehicle. Finding the police officer's stop and detention to have been wholly capricious and violative of the Fourth Amendment, the trial court granted the motion to suppress. The Delaware Supreme Court affirmed, holding that a random stop of a motorist in the absence of specific articulable facts justifying the stop by indicating a reasonable suspicion that a violation of law has occurred was constitutionally impermissible and violative of the Fourth and Fourteenth Amendments.
Was the motion to suppress evidence properly granted?
The Court affirmed the grant of a motion to suppress evidence in favor of defendant because the officer did not have a reasonable suspicion that defendant had violated the law and stopping defendant's vehicle and detaining him in order to check his driver's license and registration was unreasonable under the Fourth Amendment. The Court held that, except in those situations in which there was reasonable suspicion that a motorist was unlicensed or that an automobile was not registered, or that either the vehicle or an occupant was otherwise subject to seizure for violation of law, stopping an automobile and detaining the driver in order to check his driver's license and the registration of the automobile was unreasonable under the Fourth Amendment. The Court held that the states were not precluded from developing methods for spot checks that involved less intrusion or that did not involve the unconstrained exercise of discretion.
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