Delaware v. Prouse
Citation and Court
440 U.S. 648 (1979) — Supreme Court of the United States
Facts
A Delaware patrolman stopped an automobile at random—without any articulable suspicion of criminal activity or a traffic violation—to check the driver’s license and vehicle registration. During the stop he smelled marijuana and saw it on the car floor. He seized the marijuana and the driver was charged with possession. Prouse moved to suppress the evidence.
Issue
Does the Fourth Amendment permit police to make random, suspicionless stops of vehicles to check driver’s licenses and vehicle registration?
Holding
No; random, suspicionless vehicle stops to check licenses and registrations violate the Fourth Amendment, because the marginal interest in traffic safety does not outweigh the substantial intrusion on driver and passenger liberty.
Rule / Doctrine
Police may not randomly stop an automobile without reasonable articulable suspicion that the driver is unlicensed, the vehicle is unregistered, or either the vehicle or occupant is otherwise subject to seizure for violation of the law. Systematic, non-arbitrary programs such as fixed checkpoints may be permissible, but individualized, suspicionless stops are not.
Significance
Delaware v. Prouse establishes that the Fourth Amendment limits discretionary vehicle stops, barring arbitrary, officer-chosen stops without suspicion. It is an important counterpart to the checkpoint cases (Michigan Dept. of State Police v. Sitz), confirming that programmatic stops are treated differently from random, suspicionless stops.