Delaware v. Prouse
440 U.S. 648 (1979)
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Rule of Law:
Stopping an automobile and detaining its occupants to check the driver's license and vehicle registration constitutes an unreasonable seizure under the Fourth Amendment, unless there is at least an articulable and reasonable suspicion that a motorist is unlicensed, that an automobile is not registered, or that either the vehicle or an occupant is otherwise subject to seizure for a violation of law.
Facts:
- On November 30, 1976, a patrolman for New Castle County, Delaware, was on routine patrol in his cruiser.
- The patrolman observed an automobile occupied by respondent Prouse and decided to pull it over.
- Before initiating the stop, the patrolman did not observe any traffic violations, equipment malfunctions, or any other suspicious activity.
- The patrolman's stated purpose for the stop was solely to conduct a routine check of the driver's license and the vehicle's registration.
- The stop was not made pursuant to any departmental standards, guidelines, or procedures governing discretionary spot checks.
- Upon approaching the stopped vehicle, the patrolman smelled marihuana and saw marihuana in plain view on the car floor.
- The patrolman then seized the marihuana, which led to Prouse's indictment.
Procedural Posture:
- Prouse was indicted for illegal possession of a controlled substance in a Delaware state trial court.
- Prouse filed a motion to suppress the marihuana, arguing the evidence was obtained through an unconstitutional stop and seizure.
- The trial court granted the motion to suppress the evidence.
- The State of Delaware appealed the suppression order to the Delaware Supreme Court.
- The Delaware Supreme Court, the state's highest court, affirmed the trial court's decision, finding the stop unconstitutional.
- The State of Delaware, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does stopping an automobile on a public highway to check the driver's license and vehicle registration, without any probable cause or reasonable suspicion of illegal activity, constitute an unreasonable seizure in violation of the Fourth and Fourteenth Amendments?
Opinions:
Majority - Justice White
Yes. Stopping a vehicle and detaining its occupants constitutes a seizure under the Fourth Amendment, and the reasonableness of such a seizure is determined by balancing its intrusion on the individual's Fourth Amendment interests against its promotion of legitimate governmental interests. While the state has a vital interest in promoting highway safety through licensing and registration requirements, the practice of random, discretionary spot checks provides only a marginal contribution to this interest. The potential for these stops to create anxiety and interfere with freedom of movement, combined with the 'unbridled discretion' it places in the hands of individual officers, outweighs the state's interest. Less intrusive and more effective alternatives exist, such as stopping vehicles for observed traffic violations or conducting systematic, non-discretionary roadblock stops where all vehicles are stopped.
Dissenting - Justice Rehnquist
No. The random license check of a motorist is a minimal intrusion that is justified by the state's vital interest in ensuring highway safety. The majority's position illogically suggests the state should wait for an unlicensed driver to demonstrate their danger through a traffic violation before they can be stopped. The Court's preference for roadblock stops, where all motorists are inconvenienced, over random stops of individuals, elevates the adage 'misery loves company' to a constitutional principle. The state's enforcement method should be presumed constitutional, and the respondent failed to meet the burden of proving that this minimally intrusive procedure is unreasonable under the Fourth Amendment.
Concurring - Justice Blackmun
Yes. The majority's opinion correctly holds that purely random, discretionary stops are unconstitutional but rightly protects other, less intrusive methods from its holding. The reservation for roadblock-type stops should be understood to include other non-discretionary, systematic methods, such as stopping every tenth car. Furthermore, this case should not cast doubt on the constitutionality of different types of regulatory stops, such as those conducted by game wardens, where the balancing of interests would be quite different.
Analysis:
This decision significantly curtails the discretionary authority of police officers to conduct traffic stops. By classifying even brief, routine license checks as 'seizures,' the Court mandated that they be governed by the Fourth Amendment's reasonableness standard. The ruling established a key distinction between unconstitutional, arbitrary stops of individual vehicles and potentially constitutional, systematic methods like roadblocks. This framework has become foundational in Fourth Amendment law, shaping subsequent decisions on issues like sobriety checkpoints and other regulatory stops.
