Sunday, November 3, 2013

Whren v. United States case brief

Whren v. United States case brief summary
517 U.S. 806 (1996)

On grant of certiorari, defendants challenged a judgment of the Court of Appeals for the District of Columbia Circuit that upheld their convictions for various federal drug law violations after holding that defendants' motion for suppression was justifiably denied by the trial court. Defendants had sought suppression of evidence that was seized following a traffic stop.

Plainclothes vice-squad officers were patrolling "high drug area" in an unmarked car. An officer who had observed traffic violations approached a vehicle that was occupied by defendants. When the officer approached defendant driver's car window, he observed two large plastic bags of what appeared to be crack cocaine in defendant passenger's hands. Defendants were arrested and illegal drugs were retrieved from the vehicle.

  • On appeal, defendants accepted that the officer had probable cause to believe the traffic code was violated, but argued that the test for traffic stops should have been whether a police officer, who acted reasonably, would have made stop for the given reason. 
  • The court disagreed because the officer's motive did not apply outside the context of inventory search or administrative inspection, and performance of balancing analysis was unnecessary where probable cause existed and a traffic stop out of uniform did not remotely qualify as an extreme practice.

Judgment affirmed; officer's probable cause to believe petitioners violated traffic code rendered the vehicle stop reasonable and the evidence seized admissible.

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

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