City of Indianapolis v. Edmond Case Brief

Why is the case important?

Indianapolis set up a series of checkpoints to intercept drugs. Two motorists sued.

Facts of the case

In 1998, the City of Indianapolis began to operate vehicle checkpoints in an effort to interdict unlawful drugs. At each roadblock, one office would conduct an open-view examination of the vehicle. At the same time, another office would walk a narcotics-detection dog around the vehicle. Each stop was to last five minutes or less, without reasonable suspicion or probable cause. Both James Edmond and Joell Palmer were stopped at one of the narcotics checkpoints. They then filed a lawsuit, on their behalf and the class of motorists who had been stopped or were subject to being stopped, alleging that the roadblocks violated the Fourth Amendment and the search and seizure provision of the Indiana Constitution. The District Court denied a request for a preliminary injunction, holding that the checkpoint program did not violate the Fourth Amendment. The Court of Appeals reversed.

Question

Whether a highway checkpoint program whose primary purpose is the discovery and interdiction of illegal narcotics is constitutional.

Answer

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.

Conclusion

The Supreme Court of the United States affirmed the determination that the checkpoints violated the Fourth Amendment because the primary purpose of the narcotics checkpoint program was to uncover evidence of ordinary criminal wrongdoing. According to the Court, because the authorities pursued primarily general crime control purposes at the checkpoints, the stops could only be justified by some quantum of individualized suspicion.

  • Case Brief: 2000
  • Petitioner: City of Indianapolis
  • Respondent: Edmond
  • Decided by: Rehnquist Court

Citation: 531 US 32 (2000)
Argued: Oct 3, 2000
Decided: Nov 28, 2000