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LEGAL

RESEARCH

Whren v. United States

Facts

Plainclothes drug detectives were patrolling a known drug-use area in an unmarked police car. The officers noticed the defendantโ€™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 defendantโ€™s hands. The detective arrested the defendant and the subsequent search of the vehicle yielded several types of illegal drugs.

Issue

Whether the officerโ€™s pretextual detention of a motorist for a traffic violation rendered the seizure unreasonable under the Fourth Amendment?

Held

No. The reasonableness of the officerโ€™s seizure turns on whether the officer had the authority to make the seizure.

Discussion

The Supreme Court found probable cause that the defendantโ€™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 officersโ€™ pretextual intent in stopping the vehicle converted an otherwise reasonable police activity into an unlawful stop. While previous decisions left no doubt that the officerโ€™s motive can invalidate inventory searches and administrative inspections, the Court has never held the officerโ€™s motives relevant in any other area. The Court held that โ€œsubjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis.โ€ The seizure was lawful.

Citation

517 U.S. 806, 116 S. Ct. 1769 (1996)

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