Illinois v. Lidster
540 U.S. 419, 124 S.Ct. 885, 157 L.Ed.2d 843 (2004)
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Rule of Law:
A highway checkpoint whose primary purpose is to ask motorists for information about a specific, known crime is not per se unconstitutional under the Fourth Amendment and should be judged by a reasonableness standard that balances the public interest against the individual's liberty interests.
Facts:
- An unknown motorist traveling on a highway in Lombard, Illinois, struck and killed a 70-year-old bicyclist and drove off.
- Approximately one week later, local police set up a highway checkpoint near the same location and at the same time of night as the accident.
- The checkpoint's stated purpose was to obtain information from the motoring public about the fatal hit-and-run.
- As vehicles approached, an officer would stop each one for 10 to 15 seconds, ask the occupants if they had seen anything the previous weekend, and hand them an informational flyer.
- Robert Lidster drove his van toward the checkpoint, swerved, and nearly struck an officer.
- The officer, smelling alcohol on Lidster's breath, directed him to a side street where he was given a sobriety test and subsequently arrested for driving under the influence.
Procedural Posture:
- Robert Lidster was tried and convicted of driving under the influence of alcohol in an Illinois state trial court.
- Lidster, as appellant, appealed his conviction to an Illinois appellate court, which reversed the trial court's decision.
- The State of Illinois, as appellant, then appealed to the Illinois Supreme Court, which affirmed the appellate court's judgment, holding the checkpoint stop unconstitutional.
- The State of Illinois petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does a highway checkpoint, established for the primary purpose of soliciting information from motorists about a recent fatal hit-and-run accident, violate the Fourth Amendment's prohibition against unreasonable seizures?
Opinions:
Majority - Justice Breyer
No. A highway checkpoint established for the primary purpose of soliciting information from the public about a specific, known crime is not a per se violation of the Fourth Amendment. This type of stop is fundamentally different from the general crime control checkpoint found unconstitutional in Indianapolis v. Edmond. The primary purpose here was not to determine if the vehicle's occupants were committing a crime, but to seek their help as potential witnesses to a crime committed by someone else. The Court reasoned that such information-seeking stops are less intrusive, do not rely on individualized suspicion by their nature, and are analogous to police approaching pedestrians to ask for voluntary cooperation. The checkpoint's constitutionality is therefore judged by the balancing test from Brown v. Texas, which weighs the public concern, the degree the seizure advances that concern, and the severity of the interference with liberty. Here, the public concern (investigating a fatal crime) was grave, the method was tailored to find potential witnesses, and the intrusion on motorists was minimal, making the stop reasonable.
Concurring-in-part-and-dissenting-in-part - Justice Stevens
No, but the court should not have decided the ultimate issue of reasonableness. Justice Stevens agreed with the majority's distinction between an information-seeking checkpoint and a general crime-control checkpoint, and that Indianapolis v. Edmond does not control. However, he argued that applying the Brown v. Texas balancing test is a closer call than the majority suggests, as the seizure is still an annoying and potentially alarming intrusion for motorists, and the effectiveness of the checkpoint is speculative. Because the lower courts had not performed this balancing analysis, Justice Stevens would have remanded the case for the Illinois courts to conduct the fact-intensive reasonableness inquiry in the first instance, rather than having the Supreme Court decide it.
Analysis:
This decision carves out a significant exception to the general prohibition against suspicionless checkpoint stops established in Indianapolis v. Edmond. The Court distinguished between checkpoints for 'general crime control' (unconstitutional) and those for seeking information about a specific, known crime (potentially constitutional). By doing so, it created a new category of permissible checkpoints and clarified that the balancing test from Brown v. Texas is the appropriate framework for analysis. This provides law enforcement with a valuable investigative tool but requires courts to scrutinize such stops for reasonableness based on the gravity of the crime, the effectiveness of the stop, and the level of intrusion.
