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Illinois v. Lidster

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Brief Fact Summary. Police set up a highway checkpoint to ask motorists for information about a hit and run. Respondent was determined at the checkpoint to be driving under the influence.

Synopsis of Rule of Law. Where a stop advances a grave public concern to a significant degree, and interferes only minimally with liberty the Fourth Amendment seeks to protect.

Points of Law - Legal Principles in this Case for Law Students.

In Lidster, the Supreme Court considered whether the Fourth Amendment barred a highway checkpoint where police stopped motorists to ask them for information about a recent hit-and-run accident.

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Facts. In response to the hit-and-run death of a bicyclist, police set up a checkpoint to ask occupants if they had any information about the incident, and handed each driver a flyer about the matter. Respondent Robert Lidster’s vehicle swerved as it approached the checkpoint. A roadside sobriety test determined that the respondent was driving under the influence of alcohol.

Issue. Whether a “highway checkpoint where police stopped motorists to ask them for information” about a criminal matter complied with the Fourth Amendment.

Held. Yes. First, the Court distinguished this case from Edmond, noting that in this matter, the checkpoint “was not to determine whether a vehicle’s occupants were committing a crime but to ask vehicle occupants . . . for their help in providing information about a crime . . . committed by others.” The court dismissed the notion that “such stops normally lack individualized suspicion cannot by itself determine the constitutional outcome.” The court did “not believe that an Edmond-type rule is needed to prevent an unreasonable proliferation of police checkpoints.” On the merits of the case itself, the police were advancing a “grave” public concern with an “appropriately tailored . . . checkpoint stops to fit important criminal investigatory needs.” Finally, “the stops interfered only minimally with liberty.”

Dissent. The dissenting judges noted that “motorists who confront a roadblock are required to stop, and to remain stopped for as long as officers choose to detain them. Further, it was unlikely that questioning a “random sample of drivers” would gain any real answers.
Concurrence. Dissenting judges concurred that Edmond was not controlling.

Discussion. A checkpoint’s “reasonableness, hence, its constitutionality, [must be judged] on the basis of individual circumstances.”

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