Brief Fact Summary. Indianapolis set up a series of checkpoints to intercept drugs. Two motorists sued.
Synopsis of Rule of Law. Police must have the “usual requirement of individualized suspicion where [they] seek to employ a checkpoint primarily for the ordinary enterprise of investigating crimes.”
Issue. Whether “a highway checkpoint program whose primary purpose is the discovery and interdiction of illegal narcotics” is constitutional.
Held. No. First, the court reaffirmed that “a vehicle stop at a highway checkpoint effectuates a seizure within the meaning of Fourth Amendment.” The court also noted that it had “never approved a checkpoint program whose primary purpose was to detect evidence of ordinary criminal wrongdoing.” In response to Indianapolis’ assertion that the checkpoints “had the same ultimate purpose of arresting those suspected of committing crimes,” the Court held that “there would be little check on the ability of the authorities to construct roadblocks for almost any conceivable law enforcement purpose. Without drawing the line at roadblocks designed primarily to serve the general interest in crime control, the Fourth Amendment would do little to prevent such intrusions from becoming a routine part of the American life.” The Court also dismissed Indianapolis’ assertion that the drug problem was a social harm of the “first magnitude,” instead, opting to consider “the nature of the interests th
reatened and their connection to the particular law enforcement practices as issue.”
Rather, our checkpoint cases have recognized only limited exceptions to the general rule that a seizure must be accompanied by some measure of individualized suspicion.View Full Point of Law