Indianapolis v. Edmond (2000)

In the case of Indianapolis v. Edmond (2000), the Supreme Court restricted the power of suspicionless search, specifically with drug dogs. The court in the Edmond case rejected the argument that the severe nature of the problem justified warrantless and suspicionless stops and searches. The court in Edmond said that it had never approved a checkpoint program with the primary end of finding ordinary law violation. No matter how severe the drug problem, and the court agreed that the drug trade created highly difficult and complex law enforcement problems, the safeguarding of the individual (the requirement for reasonable suspicion of an individual) remains paramount.

Indianapolis, Indiana, in 1998 instituted vehicle checkpoints for the purpose of seizing illegal drugs. The procedure was for one officer to examine the vehicle in open view while another walked with a narcotics dog around the vehicle. The process took five minutes or less, and there was no probable cause or reasonable suspicion requirement.

The Indianapolis checkpoints were authorized to restrict the incoming flow of narcotics. Guidelines were clear and allowed the officer to stop a predetermined number of cars, question the driver and get license and registration while watching for signs of impairment. At the same time, the dog walked around each stopped vehicle. Unless suspicion appeared, the stop ended at five minutes. There was detention of the vehicle, but no seizure. Arrests occurred approximately 9 percent of the time, with nearly half on charges other than drugs.

Joell Palmer and James Edmond were stopped at one of the checkpoints and sued on their own behalf and on behalf of all motorists stopped or potentially stoppable at the roadblocks. They argued that the checkpoints violated the Fourth Amendment to the U.S. Constitution as well as the search and seizure provision of the state constitution. In denying the request for a preliminary injunction, the District Court ruled that there was no Fourth Amendment violation. The appeals court reversed the district ruling.

The Supreme Court had previously authorized police power to create roadblocks for other purposes such as border control or getting drunk drivers off the roads, both of which went beyond mere law enforcement. The Indianapolis case limited the power to specific special needs cases, instances beyond routine law enforcement.

The U.S. Supreme Court, in a 6-3 decision delivered by Justice Sandra Day O'Connor, decided that the checkpoints violated the Fourth Amendment because they were set up only as a general crime control measure, and the hope that a stop and questioning might generate indication of a crime is not sufficient. Dissenting were Justices William Rehnquist, Antonin Scalia, and Clarence Thomas, who argued that the roadblocks served [Page 381]a significant interest at minimal inconvenience to the motorist.

The Indianapolis case set limits on cases that followed the rule set down in Police v. Sitz (1990) that checkpoints were okay for ordinary crime detection. Instead, general crime control is not sufficient justification after Indianapolis; the roadblock has to have an additional justification. Sitz upheld sobriety checkpoints because their function is to increase public safety by removing an imminent threat, not to reveal criminal activity. Public safety is a reasonable constitutional ground for such stops, but detection of crime is not.

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