Whren v. United States

Whren v. United States

United States Supreme Court
517 U.S. 806 (1996)

ISSUE: Is the temporary detention of a motorist who the police have probable cause to believe has committed a civil traffic violation inconsistent with the 4th Amdt.'s prohibition against unreasonable seizures unless a reasonable officer would have been motivated to stop the car by a desire to enforce the traffic laws?
HOLDING: No, probable cause justifies a search and seizure.
FACTS:
  • Plainclothes officers were patrolling a "high drug area" of DC when they saw a truck stopped at an intersection for an "unusually long time" (more than 20 seconds)
  • When the officers went to make a U-turn, the Pathfinder turned suddenly to the right without signaling and sped off at an "unreasonable speed"
  • An officer ordered the driver to the put the car in park and then saw Whren holding two large plastic bags of what appeared to be crack cocaine
PROCEDURAL HISTORY:
  • Indicted on federal drug laws
  • Ds: Officers not justified by PC to believe or even suspect that Ds were engaged in illegal drug-dealing activity, and that the officer's grounds for approaching the vehicle were "pretextual"
  • Dist. Ct. denied suppression motion
  • Ct. App. affirmed
RULES:
  • Temporary detention of individuals during a stop = a "seizure" of "persons" under the 4th Amdt.
  • Seizures are "reasonable" where the police have PC to believe that a traffic violation has occurred
  • United States v. Robinson: The fact that the officer does not have the state of mind which is hypothecated by the reasons which provide the legal justification for the officer's action does not invalidate the action taken as long as the circumstances, viewed objectively, justify that action
REASONING:
  • Ulterior motive immaterial: Some ulterior motive of the officers cannot invalidate police conduct so long as there was a justifiable basis for PC to believe that a violation of law had occurred
    • Motive of officers only relevant in inventory and administrative searches where there is no need for PC
    • Ds agree that officers had PC to believe that traffic laws had been violated
  • "Reasonableness" not concerned with intent: The 4th Amdt.'s concern with "reasonableness" allows certain actions to be taken in certain circumstances whatever the subjective intent
    • Hypothecating about the "reasonable" officer would be speculation that would essentially subjectify the test
    • Results of test would vary from place to place based on the officers in each area
  • Private interests "outbalanced": PC to believe that the law has been broken "outbalances" private interest in avoiding police contact
  • Traffic laws not too expansive: No principle to say at what point a code of laws becomes so expansive or so commonly violated that it can no longer be enforced

 

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