Ingersoll v. Palmer

In Ingersoll v. Palmer (1987) 43 Cal.3d 1321, the court held that "within certain limitations," sobriety checkpoints may be operated without violating the Fourth Amendment to the federal Constitution or article I, section 13, of the state Constitution. (Ingersoll, supra, 43 Cal.3d at p. 1325.) In Ingersoll, the court rejected the argument that the validity of sobriety checkpoints should be analyzed under the standard set forth in In re Tony C. (1978) 21 Cal.3d 888 148 Cal.Rptr. 957, 582 P.2d 957, "requiring an individualized suspicion of wrongdoing." (Ingersoll, supra, at p. 1327.) The Ingersoll court explained the primary purpose of a sobriety checkpoint is not to detect evidence of crime or arrest drunk drivers, but to "promote public safety by deterring intoxicated persons from driving on the public streets and highways." (Id. at p. 1328.) The court concluded the validity of sobriety checkpoints "is to be determined not by the standard pertinent to traditional criminal investigative stops, but rather by the standard applicable to investigative detentions and inspections conducted as part of a regulatory scheme in furtherance of an administrative purpose." (Ibid.) After analyzing decisions pertaining to various types of seizures that did not require reasonable suspicion, the Ingersoll court held that "stops and inspections for regulatory purposes may be permitted if undertaken pursuant to predetermined specified neutral criteria." (Ingersoll, supra, 43 Cal.3d at p. 1335.) The court assessed the constitutionality of a sobriety checkpoint by "weighing the gravity of the governmental interest or public concern served and the degree to which the program advances that concern against the intrusiveness of the interference with individual liberty." (Id. at p. 1338.) The court explained that "deterring drunk driving and identifying and removing drunk drivers from the roadways undeniably serves a highly important governmental interest" (ibid.), and there is evidence sobriety checkpoints "do advance this important public goal" (id. at p. 1339).