United States v. Sharpe

United States v. Sharpe Case Brief

United States Supreme Court
470 U.S. 675 (1985)

TAG: "A 4th Amdt. seizure has to be Sharpe and to the point"
ISSUE: Was it unreasonable for officers to detain a truck for 20 minutes that they suspected was carrying marijuana while the officers tried to pulled over another vehicle?
HOLDING: No.
FACTS:
  • Agent Cooke of the DEA noticed a pickup truck with a camper top that was traveling in tandem with a Pontiac and was riding low
  • Cooke followed the cars and then radioed to highway patrol to make an investigative stop
  • The 2 cars turned off the highway, sped on a dirt road, and then turned back onto the highway
  • Highway patrol then signaled for the cars to pull over, and the Pontiac did -- they truck continued past and highway patrol pursued
  • Cooke then met up with highway patrol, who had pulled the truck over, and when the driver didn't give permission to search the truck, he took the keys and opened the back
  • Cooke found burlap sacks in the back, and when he took the truck to the federal building, they found that they contained marijuana
PROCEDURAL HISTORY:
  • Dist. Ct. refused to suppress
  • Ct. App. reversed finding that the 20-minute detention of the truck was not brief enough for the 4th Amdt.
RULES:
  • Terry v. Ohio: Reasonableness of an investigative stop:
    1. Whether the officer's action was justified at its inception; and
    2. Whether it was reasonably related to the circumstances which justified the interference in the first place.
  • Florida v. Royer: An investigative detention must be temporary and last no longer than is necessary to effectuate the purpose of the stop
REASONING:
  • No bright-line test for brevity: Must consider the law enforcement purposes to be served by the stop as well as the time reasonably needed to effectuate those purposes, so a bright-line test doesn't work
    • In assessing length, it is appropriate to examine whether the police diligently pursued a means of investigation that was likely to conform or dispel their suspicions quickly, during which time it was necessary to detain the D
  • Stop here reasonable: Given the circumstances facing Agent Cooke, he pursued his investigation in a diligent and reasonable manner
COMMENTS:
  • Delay OK because it was D's own actions that caused the delay
OTHER CASES:
  • United States v. Montoya de Hernandez: A 16-hour detention of a suspected drug smuggler in order to wait for her bowel movement upon arrival from Bogota was not unreasonable
    • Detention occurred at the international border where 4th Amdt. demands are considerably less stringent;
    • Alimentary canal smuggling, by its nature, can't be detected in the amount of time usual for a brief Terry stop;
    • Because D refused to submit to an X-ray, the only alternative was to wait;
    • D's own "heroic" efforts to resist a bowel movement extended the period of detention
  • Florida v. Royer: The investigative methods employed should be the least intrusive means reasonably available to prove or dispel the officer's suspicion in a short period of time
  • United States v. Sokolow: The reasonableness of an officer's decision to stop a suspect does not turn on the availability of less intrusive investigatory techniques
  • Hiibel v. Sixth Judicial District Court of Nevada: A state law requiring a suspect to disclose his name in the course of a valid Terry stop is consistent with the 4th Amdt.'s prohibition against unreasonable searches and seizures
  • Muehler v. Mena: An officer who has properly detained a suspect on reasonable suspicion of criminal activity does not need additional justification to ask questions about an unrelated topic so long as those questions do not increase the length of the justified detention

 

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