The Constitutionality of Sobriety (DUI) Checkpoint
In Commonwealth v. Beaman, 583 Pa. 636, 880 A.2d 578 (2005), police stopped the defendant at a sobriety checkpoint and charged him with two counts of driving under the influence.
He filed an unsuccessful motion to suppress, claiming that sobriety checkpoints (roadblocks) were per se violations of Article I, Section 8 of the Pennsylvania Constitution.
After his witness presented statistical data to the trial court, the defendant argued that roving patrols offer a practical alternative to roadblocks and, therefore, the three-factor balancing test previously applied in roadblock cases is inapplicable. Beaman at 648, 880 A.2d at 586.
On appeal to the Supreme Court, the primary question was "whether roving police patrols are more efficient at identifying and apprehending drunk drivers and, if so, whether this fatally undermines the constitutional validity of checkpoints due to the suspicionless stops that they entail." Id., 583 Pa. at 638, 880 A.2d at 579.
The Court noted that the federal and state constitutions use the same three-part balancing test to protect the same interest: "both the United States Supreme Court and this Court have recognized that the government has a compelling interest in detecting intoxicated drivers and removing them from the roads before they cause injury." Id. at 644, 880 A.2d at 583.
As to the Fourth Amendment, the Court noted that the U.S. Supreme Court has found that suspicionless stops at roadblocks are constitutionally reasonable.