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City of Indianapolis v. Edmond


The City of Indianapolis operated vehicle checkpoints to interdict unlawful drug use and transportation. At each checkpoint, the officers stopped a predetermined number of vehicles. Pursuant to written directives, an officer advised the driver that he or she was being stopped at a drug checkpoint and asked the driver to produce a license and registration. The officer looked for signs of impairment and conducted an open-view examination of the vehicle from the outside. Meanwhile, a narcotics-detection dog walked around the outside of each stopped vehicle.


Whether the checkpoint seizures without any suspicion were reasonable?


No. Previously approved suspicion-less checkpoints were approved for traffic reasons. See Michigan v. Sitz.


The Court has approved very few warrantless, suspicion-less searches and seizures. When it has done so, it was always with great uneasiness. For example, this Court has upheld brief, suspicion-less seizures at a fixed checkpoint designed to intercept illegal aliens, United States v. Martinez-Fuerte, and at a sobriety checkpoint aimed at removing drunk drivers from the road, Michigan v. Sitz. The Court has also suggested that a similar roadblock to verify drivers’ licenses and registrations would be permissible to serve a highway safety interest. Delaware v. Prouse. These checkpoints were designed to serve purposes closely related to the problems of policing the border or the necessity of ensuring roadway safety.

Here, the Court was concerned that this checkpoint program’s primary purpose was indistinguishable from the general interest in crime control. In determining whether individualized suspicion is required to accompany a seizure, the Court considers the nature of the interests threatened and their connection to the law enforcement practice. The Supreme Court is particularly reluctant to create exceptions to suspicion requirements where governmental authorities are primarily pursuing general crime control. As the Court has never approved a checkpoint program whose primary purpose was to detect evidence of ordinary criminal wrongdoing, they found the seizures here to be unreasonable.


531 U.S. 32, 121 S. Ct. 447 (2000)

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