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RESEARCH
Plainclothes drug detectives were patrolling a known drug-use area in an unmarked police car. The officers noticed the defendant’s vehicle because of its suspicious, though legal, activity. As the officers made a U-turn to get a closer look at the vehicle, it suddenly turned without signaling and sped off at an unreasonable speed. Within a short distance, the vehicle stopped behind other traffic at a red light. One plainclothes detective got out of the unmarked car, approached the vehicle, identified himself as a police officer, and directed the operator to park his vehicle. The officer acknowledged that the purpose of his direction was to get a better look at the suspect, not issue a traffic ticket. The officer observed two large plastic bags of what appeared to be crack cocaine in the defendant’s hands. The detective arrested the defendant and the subsequent search of the vehicle yielded several types of illegal drugs.
Whether the officer’s pretextual detention of a motorist for a traffic violation rendered the seizure unreasonable under the Fourth Amendment?
No. The reasonableness of the officer’s seizure turns on whether the officer had the authority to make the seizure.
The Supreme Court found probable cause that the defendant’s vehicle was involved in a traffic violation. The Court also found that the plainclothes officers would not have stopped the vehicle but for their concern that the vehicle might be involved in drug activity. As a general matter, the Court held that stopping an automobile is reasonable if the police officer has probable cause to believe that a traffic violation has occurred. Therefore, the Court was only left to consider whether the officers’ pretextual intent in stopping the vehicle converted an otherwise reasonable police activity into an unlawful stop. While previous decisions left no doubt that the officer’s motive can invalidate inventory searches and administrative inspections, the Court has never held the officer’s motives relevant in any other area. The Court held that “subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis.” The seizure was lawful.
517 U.S. 806, 116 S. Ct. 1769 (1996)
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