Supreme Court of the United States
City of Indianapolis v. Edmond
November 28, 2000531 U.S. 32
Summary
Justice O'Connor, joined by Stevens, Kennedy, Souter, Ginsburg, and Breyer, held that Indianapolis's suspicionless vehicle checkpoints violated the Fourth Amendment because their primary purpose was ordinary crime control through narcotics detection. Legitimate secondary purposes did not cure that defect, and the relevant purpose inquiry concerns the program rather than individual officers' motivations. An exterior dog sniff did not itself transform the seizure into a search. Chief Justice Rehnquist dissented, joined by Thomas and, as to Part I, Scalia, arguing that the checkpoints were objectively reasonable because they also served legitimate licensing and sobriety purposes with minimal intrusion. Thomas separately questioned the correctness of the Court's earlier checkpoint decisions but would follow them and uphold this program because respondents had not requested their overruling.
Holding
- Constitutionality of checkpoints primarily directed at ordinary crime control.. The Indianapolis narcotics checkpoints violated the Fourth Amendment because their primary purpose was to uncover evidence of ordinary criminal wrongdoing.
- Relevance of programmatic purpose and lawful secondary purposes.. Courts may examine a suspicionless checkpoint program's primary purpose, and lawful secondary licensing and sobriety purposes do not validate a program primarily directed at ordinary crime control.
- Fourth Amendment characterization of an exterior dog sniff.. Walking a narcotics-detection dog around a vehicle's exterior does not transform the checkpoint seizure into a search.
Docket 99-1030
Cited authorities
- CA10
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