City of Indianapolis v. Edmond
531 U.S. 32, 121 S. Ct. 447, 148 L. Ed.2d 333 (2000)

  • The police in Indiana set up some checkpoints to stop drugs. They pulled over random drivers and used drug sniffing dogs to search for drugs.
    • The police were instructed that they could only perform a search if they got consent or of there was some individualized suspicion (like the driver appeared to be stoned). Also, each stop was to last no longer than 5 minutes.
    • They found drugs in about 9% of the cars they pulled over!
  • Edmond, and some other people who had been stopped, sued for an injunction.
    • They argued that the stops were an unreasonable invasion of privacy and therefore barred by the 4th Amendment.
  • The Trial Court found for Indianapolis and did not issue the injunction. Edmond appealed.
  • The Appellate Court reversed and issued the injunction. Indianapolis appealed.
  • The US Supreme Court affirmed the injunction.
    • The US Supreme Court found that the suspicionless stops were not reasonable because the primary purpose of the stops was to detect evidence of ordinary criminal wrongdoing.
      • Compare to Michigan Dept. of Police v. Sitz (496 U.S. 440 (1990)), where the primary purpose was to get drunk drivers off the road, and United States v. Martinez-Fuerte (428 U.S. 453 (1976)), where the primary purpose was to stop illegal immigration.
    • Indianapolis unsuccessfully argued that the primary purpose of the checkpoint was to get intoxicated drivers off the roads, but the Court felt that the primary purpose was to find drugs, not to find intoxicated drivers.
  • In a dissent it was argued that the Court had already said it was ok to stop people at a sobriety checkpoint, and that having a dog sniff around the car was not really any more invasive, so what’s the problem?
  • The basic rule in this case is that a suspicionless search consisting of stopping people at random, without individualized suspicion or probable cause can be considered constitutional. But, it must be an administrative search.
    • An administrative search is one conducted for reasons other than ordinary criminal law enforcement.