Illinois v. Lidster Case Brief

Why is the case important?

Police set up a highway checkpoint to ask motorists for information about a hit and run. Respondent was determined at the checkpoint to be driving under the influence.

Facts of the case

“Police stopped Robert Lidster at a checkpoint set up to find information about a recent hit-and-run accident. Lidster was arrested, and later convicted, for drunk driving. Lidster successfully appealed his conviction to the Illinois Appellate Court. It relied on the U.S. Supreme Court’s decision in Indianapolis v. Edmond (2000) holding that a checkpoint is unconstitutional if its only purpose is to uncover “”ordinary criminal wrongdoing.”” The Illinois Supreme Court affirmed.”

Question

Whether a highway checkpoint where police stopped motorists to ask them for information about a criminal matter complied with the Fourth Amendment.

Answer

Yes. First, the Court distinguished this case from Edmond, noting that in this matter, the checkpoint was not to determine whether a vehicle’s occupants were committing a crime but to ask vehicle occupants . . . for their help in providing information about a crime . . . committed by others. The court dismissed the notion that such stops normally lack individualized suspicion cannot by itself determine the constitutional outcome. The court did not believe that an Edmond-type rule is needed to prevent an unreasonable proliferation of police checkpoints. On the merits of the case itself, the police were advancing a grave public concern with an appropriately tailored . . . checkpoint stops to fit important criminal investigatory needs. Finally, the stops interfered only minimally with liberty.

Conclusion

The Court held that the primary law enforcement purpose for the checkpoint stop was to ask vehicle occupants for their help in providing information about a crime committed, in all likelihood, by others. The police expected the information elicited to help them apprehend, not the vehicle’s occupants, but other individuals. An information-seeking stop was not the kind of event that involved suspicion, or lack of suspicion, of the relevant individual. A presumptive rule of unconstitutionality did not apply. Thus, the instant court had to judge the stop’s reasonableness, hence, its constitutionality, on the basis of the individual circumstances. The relevant public concern was grave because police were investigating a crime that had resulted in a human death. The stop advanced the grave public concern to a significant degree, and the police appropriately tailored their checkpoint stops to fit important criminal investigatory needs. The stops interfered only minimally with liberty of the sort the Fourth Amendment sought to protect. Each stop required only a brief wait in line. Police contact consisted simply of a request for information and the distribution of a flyer. The checkpoint stop was constitutional.

  • Case Brief: 2004
  • Petitioner: Illinois
  • Respondent: Robert S. Lidster
  • Decided by: Rehnquist Court

Citation: 540 US 419 (2004)
Granted May 5, 2003
Argued: Nov 5, 2003
Decided: Jan 13, 2004