Saturday, November 2, 2013

City of Indianapolis v. Edmond case brief

City of Indianapolis v. Edmond case brief summary
531 U.S. 32 (2000)

CASE SYNOPSIS
Petitioners filed a petition for writ of certiorari to the United States Court of Appeals for the Seventh Circuit, which reversed the denial of respondents' motion for a preliminary injunction and determined that petitioner city's checkpoint program with the primary purpose of interdicting illegal narcotics violated the Fourth Amendment, U.S. Constitutional Amendment IV.

CASE FACTS

  • Petitioner city operated vehicle checkpoints to interdict unlawful drugs. 
  • At each checkpoint location, the police stopped a predetermined number of vehicles. 
  • Pursuant to written directives, an officer advised the driver that he or she was being stopped at a drug checkpoint and asked the driver to produce a license and registration. 
  • The officer looked for signs of impairment and conducted an open-view examination of the vehicle from the outside. 
  • A narcotics-detection dog walked around the outside of each stopped vehicle. 
  • Respondents were stopped at a narcotics checkpoint and filed a class action lawsuit against petitioners, claiming that the roadblocks violated U.S. Constitutional Amendment IV. 
DISCUSSION
  • Respondents' preliminary injunction motion was denied, but this decision was reversed on appeal. 
  • On certiorari, the court affirmed the determination that the checkpoints violated U.S. Constitutional Amendment IV because the primary purpose of the narcotics checkpoint program was to uncover evidence of ordinary criminal wrongdoing. 
  • Because the authorities pursued primarily general crime control purposes at the checkpoints, the stops could only be justified by some quantum of individualized suspicion.

CONCLUSION

The court affirmed the judgment determining that the checkpoint program violated constitutional law because the primary purpose of the checkpoint program was ultimately indistinguishable from the general interest in crime control.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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