City of Indianapolis v. Edmond Case Brief
United States Supreme Court
531 U.S. 32 (2000)
ISSUE: Is a drug-detection checkpoint on a road violative of the 4th Amdt.?
- Indianapolis PD set up 6 narcotics checkpoints, which resulted in 1161 vehicles being stopped and 104 motorists being arrested
- Groups of cars were stopped, asked for license and registration, and a narcotics K9 walked around the outside of each stopped vehicle
- Dist. Ct. found that checkpoint did not violate the 4th Amdt.
- Ct. App. reversed
- Seizure/not a search: Stopping the motorists was a seizure, but the dog sniff was not a search per Place
- Program purpose contravenes 4th Amdt.: Since the primary purpose of the checkpoint was to serve the general interest of crime control, it violates the 4th Amdt. absent individualized suspicion
- Approved checkpoints have related to the important interests of policing the borders and ensuring roadway safety
- Whren doesn't apply: Whren does not preclude an inquiry into the programmatic purpose
- A drug checkpoint has the primary purpose of general crime control, which is prohibited under Michigan Dept. of State Police v. Sitz. The primary purpose must be related to the vehicle context like drunk driving (or the border context because essentially "everything goes" when it comes to the border).