Can Police Officers Randomly Stop Automobiles to Check the Validity of the Driver's License and Registration ?
In Delaware v. Prouse, 440 U.S. 648, 59 L. Ed. 2d 660, 99 S. Ct. 1391 (1979), the United States Supreme Court recognized that the inspection of licenses and registration papers is the most effective way to ensure that only those qualified to do so are permitted to operate a motor vehicle. See id. at 658-59.
In Delaware v. Prouse, the United States Supreme Court held that police officers may not, without violating the Fourth Amendment, randomly stop automobiles to check the validity of the driver's license and registration. See Prouse, 440 U.S. at 663.
There, the high Court wrote:
Accordingly, we hold that except in those situations in which there is at least articulable and reasonable suspicion that a motorist is unlicensed or that an automobile is not registered, or that either the vehicle or an occupant is otherwise subject to seizure for violation of law, stopping an automobile and detaining the driver in order to check his driver's license and the registration of the automobile are unreasonable under the Fourth Amendment. . . . We hold only that persons in automobiles on public roadways may not for that reason alone have their travel and privacy interfered with at the unbridled discretion of police officers. Id.
Following the holding in Prouse, the Court further articulated that under the Fourth Amendment, a citizen "may not be detained even momentarily without reasonable, objective grounds for doing so." Florida v. Royer, 460 U.S. 491, 498, 75 L. Ed. 2d 229, 103 S. Ct. 1319 (1983) (plurality opinion).
Additionally, the Court wrote: "The scope of the detention must be carefully tailored to its underlying justification. . . . An investigative detention must be temporary and last no longer than is necessary to effectuate the purpose of the stop." Id. at 500;
See also Cresswell v. State, 564 So. 2d 480, 481 (Fla. 1990) (holding a traffic stop may last no longer than the time it takes to write a citation).