City of Indianapolis v. Edmond, 531 U.S. 32 (2000),[1] was a United States Supreme Court case in which the Court held, 6–3, that police may not conduct vehicle searches, specifically ones involving drug-sniffingpolice dogs, at a checkpoint or roadblock without reasonable suspicion.[2] In the case, the Indianapolis Police Department was conducting warrantless searches of vehicles, without individualized suspicion, for the purpose of "general crime control".[3] Previous Supreme Court decisions had given the police power to create roadblocks for the purposes of border security (United States v. Martinez-Fuerte) and removing drunk drivers from the road (Police v. Sitz), but in this decision, the Court limited police power, holding that the search can only occur if it was designed to serve special needs, beyond the normal need for law enforcement.
121 S. Ct. 447; 148 L. Ed. 2d 333; 2000 U.S. LEXIS 8084; 69 U.S.L.W. 4009; 2000 Cal. Daily Op. Service 9549; 2000 Colo. J. C.A.R. 6401; 14 Fla. L. Weekly Fed. S 9
Police may not conduct roadblocks "whose primary purpose is to detect evidence of ordinary criminal wrongdoing." Such roadblocks must have a specific primary purpose, such as keeping roadways safe from impaired drivers, or enforcing border security.
In August 1998, the Indianapolis Police Department set up six roadblocks on roads and highways in and out of the city of Indianapolis in an effort to disrupt unlawful trafficking of illegal narcotics. The location of these roadblocks were chosen weeks in advance based on an area's crime rate and the road's general traffic flow. On written directions from the chief of police, one officer was to approach each stopped vehicle and conduct an "open-view" search of the vehicle, while another walked a narcotics-sniffing dog around the vehicle.[4] If the dog alerted to the presence of narcotics, the vehicle would be searched by the police. A predetermined number of vehicles were stopped at each roadblock, and each stop was to take five minutes or less.[5] Checkpoints were operated during daylight hours, and marked with lighted signs that read, "NARCOTICS CHECKPOINT __ MILE AHEAD, NARCOTICS K-9 IN USE, BE PREPARED TO STOP."[6] Between August and November, the police stopped 1,161 motorists, and arrested 104, of which 55 were charged with drug-related crimes.[5]
James Edmond and Joell Palmer were both stopped at one of these checkpoints, and filed a class action lawsuit against the city, representing "any and all persons driving vehicles who have been stopped [...] at the drug interdiction roadblocks maintained by the City of Indianapolis."[7]
^City of Indianapolis v. Edmond, 531U.S. 32 (2000).
^Greenhouse, Linda (January 14, 2004). "Justices Uphold Roadblocks As a Way to Find Witnesses". The New York Times. Retrieved June 21, 2022.
^"City of Indianapolis v. Edmond - 531 U.S. 32, 121 S. Ct. 447 (2000)". Law School Case Brief. LexisNexis. Retrieved June 21, 2022.
^Reeder, Doug (Summer 2003). "City of Indianapolis v. Edmond: The Supreme Court Takes a Detour to Avoid Roadblock Precedent". Houston Law Review. 40 (2): 577–608 – via HeinOnline.
^ abBateman, Samuel (Fall 2002). "Indianapolis v. Edmond: Roadblock to Fourth Amendment Erosion of Individual Security". Nevada Law Journal. 2 (3): 654–674 – via HeinOnline.
^City of Indianapolis v. Edmond, 531 U.S. at 35-36.
Text of City of Indianapolis v. Edmond, 531U.S. 32 (2000) is available from:Google ScholarJustiaLibrary of CongressOyez (oral argument audio)
April 12, 2024
city, indianapolis, edmond, 2000, united, states, supreme, court, case, which, court, held, that, police, conduct, vehicle, searches, specifically, ones, involving, drug, sniffing, police, dogs, checkpoint, roadblock, without, reasonable, suspicion, case, indi. City of Indianapolis v Edmond 531 U S 32 2000 1 was a United States Supreme Court case in which the Court held 6 3 that police may not conduct vehicle searches specifically ones involving drug sniffing police dogs at a checkpoint or roadblock without reasonable suspicion 2 In the case the Indianapolis Police Department was conducting warrantless searches of vehicles without individualized suspicion for the purpose of general crime control 3 Previous Supreme Court decisions had given the police power to create roadblocks for the purposes of border security United States v Martinez Fuerte and removing drunk drivers from the road Police v Sitz but in this decision the Court limited police power holding that the search can only occur if it was designed to serve special needs beyond the normal need for law enforcement City of Indianapolis v EdmondSupreme Court of the United StatesArgued October 3 2000Decided November 28 2000Full case nameCity of Indianapolis et al v James Edmond et al Citations531 U S 32 more 121 S Ct 447 148 L Ed 2d 333 2000 U S LEXIS 8084 69 U S L W 4009 2000 Cal Daily Op Service 9549 2000 Colo J C A R 6401 14 Fla L Weekly Fed S 9Case historyPriorEdmond v Goldsmith 38 F Supp 2d 1016 S D Ind 1998 reversed 183 F 3d 659 7th Cir 1999 cert granted 528 U S 1153 2000 HoldingPolice may not conduct roadblocks whose primary purpose is to detect evidence of ordinary criminal wrongdoing Such roadblocks must have a specific primary purpose such as keeping roadways safe from impaired drivers or enforcing border security Court membershipChief Justice William Rehnquist Associate Justices John P Stevens Sandra Day O ConnorAntonin Scalia Anthony KennedyDavid Souter Clarence ThomasRuth Bader Ginsburg Stephen BreyerCase opinionsMajorityO Connor joined by Stevens Kennedy Souter Ginsburg BreyerDissentRehnquist joined by Thomas Scalia only as to Part I DissentThomasLaws appliedU S Const amend IV Contents 1 Background 2 Opinion of the Court 3 See also 4 References 5 External linksBackground editIn August 1998 the Indianapolis Police Department set up six roadblocks on roads and highways in and out of the city of Indianapolis in an effort to disrupt unlawful trafficking of illegal narcotics The location of these roadblocks were chosen weeks in advance based on an area s crime rate and the road s general traffic flow On written directions from the chief of police one officer was to approach each stopped vehicle and conduct an open view search of the vehicle while another walked a narcotics sniffing dog around the vehicle 4 If the dog alerted to the presence of narcotics the vehicle would be searched by the police A predetermined number of vehicles were stopped at each roadblock and each stop was to take five minutes or less 5 Checkpoints were operated during daylight hours and marked with lighted signs that read NARCOTICS CHECKPOINT MILE AHEAD NARCOTICS K 9 IN USE BE PREPARED TO STOP 6 Between August and November the police stopped 1 161 motorists and arrested 104 of which 55 were charged with drug related crimes 5 James Edmond and Joell Palmer were both stopped at one of these checkpoints and filed a class action lawsuit against the city representing any and all persons driving vehicles who have been stopped at the drug interdiction roadblocks maintained by the City of Indianapolis 7 Opinion of the Court editThe opinion was delivered by Justice O Connor joined by Justices Stevens Kennedy Souter Ginsburg and Breyer Chief Justice Rehnquist delivered a dissenting opinion in which Justice Thomas joined and Justice Scalia joined as to part I Justice Thomas also filed a separate dissent See also editList of United States Supreme Court cases volume 531 United States v Martinez Fuerte 1976 Michigan Dept of State Police v Sitz 1990 Illinois v Lidster 2004 References edit City of Indianapolis v Edmond 531 U S 32 2000 Greenhouse Linda January 14 2004 Justices Uphold Roadblocks As a Way to Find Witnesses The New York Times Retrieved June 21 2022 City of Indianapolis v Edmond 531 U S 32 121 S Ct 447 2000 Law School Case Brief LexisNexis Retrieved June 21 2022 Reeder Doug Summer 2003 City of Indianapolis v Edmond The Supreme Court Takes a Detour to Avoid Roadblock Precedent Houston Law Review 40 2 577 608 via HeinOnline a b Bateman Samuel Fall 2002 Indianapolis v Edmond Roadblock to Fourth Amendment Erosion of Individual Security Nevada Law Journal 2 3 654 674 via HeinOnline City of Indianapolis v Edmond 531 U S at 35 36 Goldsmith 38 F Supp 2d S D Ind 1998 at 1020 External links editText of City of Indianapolis v Edmond 531 U S 32 2000 is available from Google Scholar Justia Library of Congress Oyez oral argument audio Retrieved from https en wikipedia org w index php title City of Indianapolis v Edmond amp oldid 1175140289, wikipedia, wiki, book, books, library,
