Indianapolis v. Edmond
Citation and Court
531 U.S. 32 (2000) — Supreme Court of the United States
Facts
Indianapolis established vehicle checkpoints at which officers stopped motorists, looked for signs of impairment, and walked a narcotics dog around each vehicle. The stated primary purpose was drug interdiction. Motorists challenged the program as unconstitutional.
Issue
Whether a checkpoint program whose primary purpose is the discovery and interdiction of illegal narcotics violates the Fourth Amendment.
Holding
The drug-interdiction checkpoints violated the Fourth Amendment because their primary purpose was ordinary crime control, not a special need beyond normal law enforcement.
Rule / Doctrine
A checkpoint program whose primary purpose is to detect evidence of ordinary criminal wrongdoing is unconstitutional without individualized suspicion. The special-needs exception (permitting suspicionless stops for sobriety, border enforcement, etc.) does not apply when the program’s primary purpose is general crime detection. Distinguished from Michigan Dep’t of State Police v. Sitz (sobriety checkpoints) and United States v. Martinez-Fuerte (border checkpoints).
Significance
Set a clear limit on suspicionless checkpoint stops: the government cannot use the checkpoint exception as a general tool of law enforcement. The “primary purpose” test is the key analytical framework for evaluating checkpoint programs.