In People v. Scott (63 NY2d 518 [1984]) a sobriety checkpoint was established in accordance with a detailed, written memorandum formulated by the highest ranking law enforcement officer in the county, the Sheriff. The memorandum detailed the need for sobriety checkpoints "at known DWI and high accident locations during [specified] peak hours" and contained explicit guidelines related to: "site selection, lighting and signs; avoidance of discrimination by stopping all vehicles, or every second, third or fourth vehicle; location of screening areas off the highway to which vehicles would be directed; the nature of the inquiries to be made, with specific direction . . . It also directed that checkpoint sites be prescreened and that from two to four locations be used during a four-hour period." (Id. at 523.) In upholding the program, the Court stated "individualized suspicion is not a prerequisite to a constitutional seizure of an automobile which is carried out pursuant to a plan embodying explicit, neutral limitations on the conduct of individual officers." (Id. at 525.) The Court, noting the importance of the governmental interest in addressing "the carnage caused by drunk drivers," stated: "In light of the specific procedures devised and promulgated to law enforcement personnel by the head of their department, the Sheriff, and the way in which the particular roadblock was being operated when defendant was stopped, the courts below could properly conclude that it did not intrude to an impermissible degree upon the privacy of motorists approaching the checkpoint, that it was being maintained in accordance with a uniform procedure which afforded little discretion to operating personnel, and that adequate precautions as to safety, lighting and fair warning of the existence of the checkpoint were in operation." (Id. at 526.) In Scott, the checkpoint was executed in accordance with a written plan formulated by the county's highest law enforcement official. The Court of Appeals approved of sobriety checkpoints. In that case, written directives had established procedures for site selection and avoidance of discrimination by stopping every vehicle, or every second, third, or fourth vehicle. Id. at 523-524. In Scott, although the Court of Appeals approved of the written plan at issue, it did not expressly hold that the plan or directive used by police in the selection and operation of a checkpoint had to be in writing. The Court of Appeals noted, that in that case "two patrol cars were stationed in the area to follow and observe for possible violations any vehicle that avoided the road block by making a U-turn." One must note that the guidelines established in that case permitted only the following and observation for possible violations of any vehicle that avoided the checkpoint. The U-turn, in and of itself, did not in the Scott case amount to a reason to stop any vehicle. In other words, if not normally prohibited at that site, a legal U-turn was not an articulable reason to stop a vehicle.