United States v. Sharpe Case Brief

Why is the case important?

Three individuals were arrested after a car and a truck were pulled over on the highway. A substantial amount of marijuana was found in the truck. The arrests did not take occur until thirty or forty minutes after the cars were pulled over.

Facts of the case

Question

Whether an individual reasonably suspected of engaging in criminal activity may be detained for a period of 20 minutes, when the detention is necessary for law enforcement officers to conduct a limited investigation of the suspected criminal activity?

Answer

“The majority found that Terry applied here. It observed it is not necessary for us to decide whether the length of Sharpe’s detention was unreasonable, because that detention bears no causal relation to the DEA agent’s discovery of the marihuana. The marihuana was in the Respondent’s pickup, not in Sharpe’s Pontiac

  • the contraband introduced at respondents’ trial cannot logically be considered the ‘fruit’ of Sharpe’s detention. The majority concluded that the detention of the Respondent clearly meets the Fourth Amendment’s standard of reasonableness.”

    Conclusion

    The Court held that the detention in question met the Fourth Amendment’s standard of reasonableness. According to the Court, in assessing whether a police detention was too long in duration to be justified as an investigative stop, it was appropriate to examine whether the officer diligently pursued a means of investigation that was likely to confirm or dispel his suspicions quickly, during which time it was necessary to detain defendants. The Court held that because the officer pursued his investigation of defendants in a diligent and reasonable manner, and the delay was attributable almost entirely to the evasive actions of one defendant, the 20-minute stop was not violative of the Fourth Amendment.

    • Case Brief: 1985
    • Petitioner: United States
    • Respondent: Sharpe
    • Decided by: Burger Court

    Citation: 470 US 675 (1985)
    Argued: Nov 27, 1984
    Decided: Mar 20, 1985