Delaware v. Prouse Case Brief

Facts of the Case

A New Castle County, Delaware, police officer stopped an automobile and seized marijuana in plain view on the car floor after smelling marijuana smoke as he walked toward the stopped vehicle. An occupant of the vehicle who had been indicted for illegal possession of a controlled substance moved to suppress, at his state trial, the marijuana seized as a result of the stop. At a hearing on the motion to suppress, the police officer testified that prior to stopping the vehicle, no traffic or equipment violations nor any suspicious activity had occurred. In fact, the police officer only made the stop in order to check the driver’s license and the registration of the vehicle. Finding the police officer’s stop and detention to have been wholly capricious and violative of the Fourth Amendment, the trial court granted the motion to suppress. The Delaware Supreme Court affirmed, holding that a random stop of a motorist in the absence of specific articulable facts justifying the stop by indicating a reasonable suspicion that a violation of law has occurred was constitutionally impermissible and violative of the Fourth and Fourteenth Amendments.




“Yes. In an 8-to-1 decision, the Court held that the privacy interests of travelers outweighed the state interests in discretionary spot checks of automobiles. The Court found that random checks made only marginal contributions to roadway safety and compliance with registration requirements