Indianapolis v. Edmond

In Indianapolis v. Edmond (2000) 531 U.S. 32, defendant challenged a highway checkpoint employed by law enforcement in Indianapolis, the primary purpose of which was to identify persons transporting drugs. Under the program, police would stop vehicles momentarily, ostensibly to ask the driver for license and registration. During the stop, a dog trained to locate drugs would check the car from the outside. (Edmond, supra, 531 U.S. 32, 35.) The court found a "difference in the Fourth Amendment significance of highway safety interests and the general interest in crime control." (Id. at p. 40.) The court stated the primary purpose of the Indianapolis checkpoint program was interdicting drugs, even though it also had the effect of reducing the number of unsafe drivers. (Id. at pp. 41-42.) Since the program's primary purpose was general crime control, individual suspicion was required, notwithstanding the secondary effect. (Id. at pp. 46-47.) In Edmond, the Supreme Court--having previously upheld brief, suspicionless seizures at highway checkpoints for the purposes of combating drunk driving and intercepting illegal immigrants--considered the constitutionality of a highway checkpoint program whose primary purpose was the discovery and interdiction of illegal narcotics. ( Edmond, supra, 531 U.S. at p. 34.) The Supreme Court emphasized that, in the border case, the considerations specifically related to the need to police the border were a significant factor in its decision. Similarly, the drunk driving checkpoints were aimed at reducing the immediate hazard posed by the presence of drunk drivers on the highways, and there was a clear connection between highway safety and the law enforcement practice at issue. ( Id. at pp. 38-39.) The gravity of the drunk driving problem and the magnitude of the state's interest in getting intoxicated drivers off the road weighed heavily in the high court's determination that the checkpoint program was constitutional. ( Id. at p. 39.) The court pointed to the "difference in the Fourth Amendment significance of highway safety interests and the general interest in crime control" ( id. at p. 40), and stated: "We have never approved a checkpoint program whose primary purpose was to detect evidence of ordinary criminal wrongdoing. Rather, our checkpoint cases have recognized only limited exceptions to the general rule that a seizure must be accompanied by some measure of individualized suspicion. We suggested ... that we would not credit the 'general interest in crime control' as justification for a regime of suspicionless stops. Consistent with this suggestion, each of the checkpoint programs that we have approved was designed primarily to serve purposes closely related to the problems of policing the border or the necessity of ensuring roadway safety. Because the primary purpose of the Indianapolis narcotics checkpoint program is to uncover evidence of ordinary criminal wrongdoing, the program contravenes the Fourth Amendment." ( Id. at pp. 41-42.) The court recognized the "daunting and complex" problems created by the drug trade ( id. at p. 42), but determined that "the gravity of the threat alone cannot be dispositive of questions concerning what means law enforcement officers may employ to pursue a given purpose. Rather, in determining whether individualized suspicion is required, we must consider the nature of the interests threatened and their connection to the particular law enforcement practices at issue. We are particularly reluctant to recognize exceptions to the general rule of individualized suspicion where governmental authorities primarily pursue their general crime control ends." ( Id. at pp. 42-43.) The court declined "to suspend the usual requirement of individualized suspicion where the police seek to employ a checkpoint primarily for the ordinary enterprise of investigating crimes or to sanction stops justified only by the generalized and ever-present possibility that interrogation and inspection may reveal that any given motorist has committed some crime." ( Id. at p. 44.) In Indianapolis v. Edmond (2000) the issue was whether a highway checkpoint program whose primary purpose was discovery and interdiction of illegal narcotics violated the Fourth Amendment. The Supreme Court began by reiterating the current state of Fourth Amendment jurisprudence. "The Fourth Amendment requires that searches and seizures be reasonable. A search or seizure is ordinarily unreasonable in the absence of individualized suspicion of wrongdoing. While such suspicion is not an 'irreducible' component of reasonableness, we have recognized only limited circumstances in which the usual rule does not apply. For example, we have upheld certain regimes of suspicionless searches where the program was designed to serve 'special needs, beyond the normal need for law enforcement.' We have also allowed searches for certain administrative purposes without particularized suspicion of misconduct, provided that those searches are appropriately limited. "We have also upheld brief, suspicionless seizures of motorists at a fixed Border Patrol checkpoint designed to intercept illegal aliens, , and at a sobriety checkpoint aimed at removing drunk drivers from the road, . In addition, ... we suggested that a similar type of roadblock with the purpose of verifying drivers' licenses and vehicle registrations would be permissible. In none of these cases, however, did we indicate approval of a checkpoint program whose primary purpose was to detect evidence of ordinary criminal wrongdoing." (Indianapolis v. Edmond, supra, 531 U.S. at pp. 37-38.) The Supreme Court emphasized in the border patrol case that the considerations specifically related to the need to police the border were a significant factor. (Indianapolis v. Edmond, supra, 531 U.S. at pp. 38-39.)