Tuesday, November 5, 2013

Illinois v. Caballes case brief

Illinois v. Caballes case brief summary
543 U.S. 405 (2005)

A state trooper stopped respondent for speeding. A second trooper drove to the scene with his dog and walked the dog around respondent's car while the first trooper wrote a warning ticket. When the dog alerted at respondent's trunk, the officers searched the trunk and found marijuana. Respondent's motion to suppress was denied at his drug trial. The Illinois Supreme Court reversed. Petitioner State's petition for a writ of certiorari was granted.


  • The U.S. Supreme Court granted certiorari on the question of whether the Fourth Amendmentrequired reasonable, articulable suspicion to justify using a drug-detection dog to sniff a vehicle during a legitimate traffic stop. 
  • The state trial court concluded that the duration of the stop was entirely justified by the traffic offense and the ordinary inquiries incident to such a stop. 
  • The state supreme court concluded that because the canine sniff was performed without any specific and articulable facts to suggest drug activity, the use of the dog unjustifiably enlarged the scope of a routine traffic stop into a drug investigation. 
  • The U.S. Supreme Court held that the use of a well-trained narcotics-detection dog--one that did not expose noncontraband items that otherwise would have remained hidden from public view--during a lawful traffic stop, generally did not implicate legitimate privacy interests. 
  • The dog sniff was performed on the exterior of respondent's car while he was lawfully seized for a traffic violation. 
  • Any intrusion on respondent's privacy expectations did not rise to the level of a constitutionally cognizable infringement.

The judgment was vacated, and the case was remanded for further proceedings.

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

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