Indianapolis vs. Edmond

531 U.S. 32, 121S. ct.447, 148 L. Ed. 2D 333(2000)

Facts: In an attempt to discover and intercept unlawful narcotics on transit across the city, Indianapolis police implemented a highway checkpoint program, where motorists would be stopped at designated checkpoints, and their vehicles searched for narcotics. The checks lasted no more than five minutes and involved both an open-view examination, and a sniffer dog program. Two motorists, one of them James Edmond, brought suit against the state on grounds that the checkpoint program violated the search and seizure provisions of both the Indiana Constitution and the Fourth Amendment (Carmen, 2013).

Is a highway checkpoint program whose primary goal is the discovery and interception of unlawful drugs consistent with the provisions of the Fourth Amendment?

Holding: No; a vehicle examination at a highway checkpoint constitutes an unlawful search, particularly if the purpose of the same is indistinguishable from the overall interest in controlling crime.

Dissent: three judges dissented on grounds that the program served the interest of the state, with only very minimal intrusion on privacy, and that it could not be termed unconstitutional just because of the dual purpose of crime control. Justice Clarence Thomas expressed doubt over the correctness of past decisions, which the court had used to influence its decision.

Reasoning: the Supreme Court established that since the checkpoint program was based on the need to obtain evidence of ordinary criminal activity, it was subject to the search and seizure provisions of the Fourth Amendment. If such highway checks were approved just because they would assist police in obtaining evidence of criminal activity, then there would be no reason why they wouldn't do the same to intercept suspects of any other ordinary criminal activity. In the end, police intrusion would become a routine part of citizens' lives. There is an ever-present possibility that inspections and interrogations may reveal that a given motorist is engaging in unlawful activity, and the justification of highway checks cannot, therefore, be based solely on this possibility.

Significance: this was a landmark ruling, which expanded the scope and the practical protections of the Fourth Amendment to an activity that most people considered normal.

References

Carmen, R. (2013). Criminal Procedure: Law and Traffic (9th ed.). Belmont, CA: Cengage Learning.