Illinois v. Lidster
Citation and Court
540 U.S. 419 (2004) — Supreme Court of the United States
Facts
Police set up a highway checkpoint to seek information from motorists about a recent hit-and-run accident that had killed a bicyclist. Lidster was stopped at the checkpoint, and after an officer smelled alcohol, he was arrested for drunk driving. He sought to suppress the evidence, arguing the checkpoint was unconstitutional.
Issue
Whether a highway checkpoint designed to obtain information from the public about a recent serious crime violates the Fourth Amendment.
Holding
The information-seeking checkpoint was constitutional; brief stops to ask motorists for help investigating a recent crime do not violate the Fourth Amendment.
Rule / Doctrine
Not all checkpoints are governed by the Indianapolis v. Edmond rule against primary-purpose crime detection. Information-seeking checkpoints aimed at soliciting witness information about a past crime are assessed under general Fourth Amendment reasonableness balancing and can be constitutional.
Significance
Distinguished Edmond by clarifying that the prohibition on crime-detection checkpoints applies to those aimed at discovering ongoing criminality, not those seeking witnesses to past crimes. Established that context and purpose matter in checkpoint analysis.