City of Indianapolis v. Edmond
531 U.S. 32 (2000)
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Rule of Law:
A suspicionless vehicle checkpoint program violates the Fourth Amendment if its primary purpose is indistinguishable from the general interest in crime control, such as discovering and interdicting illegal narcotics.
Facts:
- In August 1998, the city of Indianapolis began operating vehicle checkpoints on public roads.
- The stated primary purpose of these checkpoints was to interdict unlawful drugs.
- Signs identified the stops as a 'NARCOTICS CHECKPOINT' where a 'NARCOTICS K-9 [was] IN USE.'
- At a stop, an officer would ask the driver for their license and registration while also looking for signs of impairment.
- A narcotics-detection dog would then walk around the exterior of each stopped vehicle.
- Stops were brief, designed to last five minutes or less unless particularized suspicion arose.
- James Edmond and Joell Palmer were each motorists stopped at one of these narcotics checkpoints in September 1998.
Procedural Posture:
- James Edmond and Joell Palmer filed a class-action lawsuit against the city of Indianapolis in the United States District Court for the Southern District of Indiana.
- The plaintiffs alleged the drug checkpoints violated the Fourth Amendment and sought injunctive and declaratory relief.
- The plaintiffs moved for a preliminary injunction to halt the checkpoints.
- The District Court denied the motion for a preliminary injunction, holding the checkpoint program was constitutional.
- The plaintiffs, as appellants, appealed the District Court's decision to the United States Court of Appeals for the Seventh Circuit.
- A divided panel of the Seventh Circuit reversed the District Court, finding the checkpoints unconstitutional.
- The city of Indianapolis, as petitioner, successfully petitioned the United States Supreme Court for a writ of certiorari.
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Issue:
Does a highway checkpoint program, whose primary purpose is the discovery and interdiction of illegal narcotics, violate the Fourth Amendment's prohibition against unreasonable seizures?
Opinions:
Majority - Justice O’Connor
Yes, a highway checkpoint program whose primary purpose is the discovery and interdiction of illegal narcotics violates the Fourth Amendment. While the Court has previously upheld suspicionless checkpoints for specific purposes like combating drunk driving (Michigan v. Sitz) and intercepting illegal immigrants near the border (United States v. Martinez-Fuerte), those exceptions were closely related to roadway safety and border protection. The primary purpose of the Indianapolis program is general crime control, which is not a permissible justification for a suspicionless seizure regime. The gravity of the drug problem alone cannot justify suspending the Fourth Amendment's general requirement of individualized suspicion. To permit a checkpoint whose primary purpose is ordinary criminal investigation would create an exception that would swallow the rule, allowing such intrusions to become a routine part of American life. The constitutionality of such a program depends on its programmatic purpose, not the subjective intent of individual officers.
Dissenting - Chief Justice Rehnquist
No, the checkpoint program does not violate the Fourth Amendment. The checkpoints have legitimate secondary purposes, such as checking driver's licenses and looking for signs of impairment, which are independently constitutional under Delaware v. Prouse and Michigan v. Sitz. Because the roadblocks are objectively reasonable in serving these substantial state interests with minimal intrusion, their constitutionality should not be invalidated by an inquiry into their 'primary purpose.' Under Whren v. United States, the subjective motivations of law enforcement are irrelevant when there is an objective justification for their actions. The addition of a drug-sniffing dog, which does not constitute a 'search' and does not lengthen the stop, does not render an otherwise constitutional seizure unlawful.
Dissenting - Justice Thomas
No, the checkpoint program should be upheld based on existing precedent, though the precedent itself is questionable. I doubt that the Framers of the Fourth Amendment would have considered indiscriminate, suspicionless stops of individuals to be 'reasonable.' However, Michigan v. Sitz and United States v. Martinez-Fuerte are the controlling precedents. As I am reluctant to reconsider those decisions without full briefing and argument, I believe they compel the conclusion that the program at issue here is constitutional, and I therefore join the Chief Justice's dissent.
Analysis:
This decision established the 'primary purpose test' for analyzing the constitutionality of suspicionless vehicle checkpoints. It drew a critical line between checkpoints aimed at specific, immediate public safety threats related to the roadway or border, and those aimed at general law enforcement. By invalidating checkpoints for general crime control, the Court significantly limited the ability of police to use this exception to the warrant requirement as a broad tool for criminal investigation. Future litigation over checkpoints now centers on identifying the programmatic purpose of the stop, protecting motorists from being subjected to routine, suspicionless seizures for general criminal investigation.
