Whren v. United States

In Whren v. United States (1996) 517 U.S. 806, the petitioners argued that the balancing inherent in any Fourth Amendment inquiry required the Supreme Court to weigh the governmental and individual interests implicated in a traffic stop. ( Whren v. United States, supra, 517 U.S. at p. 816.) The Supreme Court held: "Where probable cause has existed, the only cases in which we have found it necessary actually to perform the 'balancing' analysis involved searches or seizures conducted in an extraordinary manner, unusually harmful to an individual's privacy or even physical interests--such as, for example, seizure by means of deadly force unannounced entry into a home entry into a home without a warrant, or physical penetration of the body." ( Id. at p. 818.) The court concluded: "The making of a traffic stop out of uniform does not remotely qualify as such an extreme practice, and so is governed by the usual rule that probable cause to believe the law has been broken 'outbalances' private interest in avoiding police contact." (Ibid.) The court rejected the argument that "the constitutional reasonableness of traffic stops depends on the actual motivations of the individual officers involved." (Ibid.) The court explained, "Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis." (Ibid.) Thus," 'the fact that the officer does not have the state of mind which is hypothecated by the reasons which provide the legal justification for the officer's action does not invalidate the action taken as long as the circumstances, viewed objectively, justify that action.'" (Ibid.) The United States Supreme Court held that the temporary detention of a motorist upon probable cause to believe that he has violated the traffic laws does not violate the Fourth Amendment's prohibition against unreasonable seizures, even if a reasonable officer would not have stopped the motorist absent some additional law enforcement objective. The Court went on to state that it believed its prior decisions in United States v. Villamonte-Marquez (462 US 579 1983), United States v. Robinson (414 US 218 1973), and Scott v. United States (436 US 128 1978) served to "foreclose any argument that the constitutional reasonableness of traffic stops depends on the actual motivations of the individual officers involved," and further iterated that "subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis" (Whren v. United States, supra, at 813). The Supreme Court recognized that the Fourth Amendment's reasonable requirement is fulfilled and a law enforcement officer may constitutionally stop the driver of a vehicle when the officer possesses probable cause to believe that the driver of the vehicle has committed a traffic violation. Id. The court stated: "Temporary detention of individuals during the stop of an automobile by the police, even if only for a brief period and for a limited purpose, constitutes a seizure of 'persons' within the meaning of the Fourth Amendment. An automobile stop is thus subject to the constitutional imperative that it not be 'unreasonable' under the circumstances. As a general matter, the decision to stop an automobile is reasonable where the police have probable cause to believe that a traffic violation has occurred." Id. at 809-10 The U.S. Supreme Court determined that the constitutional reasonableness of an ostensible traffic stop did not depend "on the actual motivations of the individual officers involved." (Id. at p. 813.) The court stated: "Not only have we never held, outside the context of inventory search or administrative inspection . . . that an officer's motive invalidates objectively justifiable behavior under the Fourth Amendment; but we have repeatedly held and asserted the contrary." (Id. at p. 812.) The court repeated its statement in an earlier opinion that " 'the fact that the officer does not have the state of mind which is hypothecated by the reasons which provide the legal justification for the officer's action does not invalidate the action taken as long as the circumstances, viewed objectively, justify that action.' " (Id. at p. 813.) Finally, the court declared: "Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis." (Ibid.)