Whren v. United States
517 U.S. 806, 116 S.Ct. 1769 (1996)
Rule of Law:
Under the Fourth Amendment, a police officer's subjective motivations are irrelevant to the reasonableness of a traffic stop, so long as the stop is supported by objectively reasonable probable cause to believe that a traffic violation has occurred.
Facts:
- Plainclothes vice-squad officers in an unmarked car were patrolling a 'high drug area' in Washington, D.C.
- The officers observed a dark Pathfinder truck with temporary license plates and youthful occupants stopped at an intersection for an unusually long time, over 20 seconds.
- The driver of the truck was looking down into the lap of the passenger, petitioner Whren.
- When the officers' car made a U-turn to head back towards the Pathfinder, the truck turned suddenly to its right without signaling.
- The Pathfinder then sped off at what the officers described as an 'unreasonable' speed.
- The officers overtook the Pathfinder at a red light, and Officer Soto approached the driver's side.
- Upon reaching the driver's window, Officer Soto immediately observed two large plastic bags of what appeared to be crack cocaine in Whren's hands.
Procedural Posture:
- Petitioners Whren and Brown were charged with violating federal drug laws in the U.S. District Court for the District of Columbia.
- At a pretrial hearing, petitioners filed a motion to suppress the drug evidence, arguing the traffic stop was an unconstitutional pretextual stop.
- The District Court (trial court) denied the motion to suppress.
- Petitioners were convicted of the drug charges.
- Petitioners (as appellants) appealed their convictions to the U.S. Court of Appeals for the D.C. Circuit, with the United States as the appellee.
- The Court of Appeals affirmed the convictions, holding that a traffic stop is permissible as long as a reasonable officer could have stopped the car for the suspected traffic violation.
- The U.S. Supreme Court granted certiorari to review the Court of Appeals' decision.
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Issue:
Does the Fourth Amendment's protection against unreasonable seizures prohibit police from stopping a motorist for a traffic violation, for which they have probable cause, if the officer's actual motivation is to investigate a different, unrelated crime?
Opinions:
Majority - Justice Scalia
No. The constitutional reasonableness of a traffic stop under the Fourth Amendment does not depend on the actual motivations of the individual officers involved. As long as there is an objective legal justification for the action, such as probable cause to believe a traffic law has been violated, the stop is reasonable. The Court reasoned that prior cases have consistently held that an officer's subjective motive does not invalidate objectively justifiable behavior under the Fourth Amendment. Cases disapproving of 'pretextual' searches, such as those involving inventory or administrative searches, were distinct because they were conducted in the absence of probable cause. Here, because the officers had probable cause to believe the petitioners had committed multiple traffic violations (failing to signal, speeding, and failing to give full attention to driving), the stop was objectively reasonable. The Court rejected the petitioners' proposed test of whether a 'reasonable officer' would have made the stop for the given reason, calling it an impractical and subjective inquiry. The proper recourse for claims of selective enforcement based on factors like race, the Court noted, lies in the Equal Protection Clause, not the Fourth Amendment.
Analysis:
This unanimous decision solidifies the objective standard for Fourth Amendment analysis of traffic stops, effectively authorizing 'pretextual stops.' The ruling grants law enforcement significant discretion, as officers can stop a vehicle for any observed minor traffic infraction, even if their true motive is to investigate a hunch about more serious criminal activity. This significantly impacts police practices by removing judicial inquiry into officer's subjective intent in these common encounters. While the Court directed claims of racial profiling to the Equal Protection Clause, this decision has been criticized for making such claims harder to prove while potentially enabling discriminatory enforcement practices under the guise of traffic law.
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