Illinois v. Lidster

Illinois v. Lidster Case Brief

United States Supreme Court
540 U.S. 419 (2004)

ISSUE: Is a highway checkpoint for information-gathering about a crime that had occurred a week before unreasonable under the 4th Amdt.?
HOLDING: No.
FACTS:
  • A 70-year-old bicyclist was killed by a hit-and-run driver
  • One week later, police set up a highway checkpoint where all cars were stopped and asked about the crime and given a flyer
  • D swerved as he approached the checkpoint and nearly hit an officer -- he was arrested for DUI
PROCEDURAL HISTORY:
  • Trial Ct. found that the checkpoint did not violate the 4th Admt.
  • Ct. App. reversed and Sup. Ct. affirmed
REASONING:
  • Not unconstitutional under Edmond: The stop's purpose here was information-gathering and not determining if the vehicles' occupants had committed crimes themselves
    • Information-seeking stops don't require individualized suspicion
    • Less likely to provoke anxiety
    • Police may always approach individuals and ask them about crimes
    • Edmond-type rule is not needed to prevent the proliferation of these checkpoints (limited resources and community hostility)
  • Reasonable stop: Police appropriately tailored the checkpoint stops to fit important criminal investigatory needs
COMMENTS:
  • Highway checkpoints for information-gathering under situations similar to Lidster do not violate the Fourth Amendment. Note that these stops are not designed to necessarily incriminate the drivers (quite unlike the DUI checkpoint in Sitz), so they seem more palatable. According to the Supreme Court, lack of resources and community outrage will limit the proliferation of these types of stops, not the Constitution.

 

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