Academic journal article Journal of Criminal Law and Criminology

City of Indianapolis V. Edmond: The Constitutionality of Drug Interdiction Checkpoints

Academic journal article Journal of Criminal Law and Criminology

City of Indianapolis V. Edmond: The Constitutionality of Drug Interdiction Checkpoints

Article excerpt

City of Indianapolis v. Edmond, 531 U.S. 32 (2001).

I. INTRODUCTION

In City of Indianapolis v. Edmond, (1) the Supreme Court ruled on the constitutionality of a drug interdiction program operated in Indianapolis. The Supreme Court held that the drug interdiction checkpoints were unconstitutional violations of the Fourth Amendment because the primary purpose of the checkpoints was general crime control.

This Note argues that the decision in Edmond was incorrect. The previous roadblock cases of United States v. Martinez-Fuerte (2) and Michigan Department of State Police v. Sitz (3) clearly established that roadblocks in certain situations are constitutional, and the roadblocks at issue in Indianapolis were not sufficiently distinguishable to warrant a contrary outcome. Had the Court followed the principles it set forth in earlier roadblock cases, it would have been forced to uphold the drug interdiction checkpoints as constitutional. Instead, the majority of the Court created an arbitrary distinction that has no basis in prior case law or in the wording of the Fourth Amendment. As a result, current roadblock case law has become confusing and illogical--the Court solved nothing and despite its attempt to preserve individual liberties under the Fourth Amendment, the Court failed. States can easily circumvent the Court's decision and establish roadblocks identical to the roadblocks struck down in Edmond simply by taking care to articulate a primary purpose that the Court has deemed acceptable. As a result, the Court's promise to protect Fourth Amendment rights is hollow and illusory. Increased litigation and uncertainty about the types of roadblocks that are constitutional will likely result.

II. BACKGROUND

A. THE FOURTH AMENDMENT PROHIBITION AGAINST UNREASONABLE SEARCHES AND SEIZURES

The Fourth Amendment states: "The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated...." (4) The Supreme Court has generally held that the Fourth Amendment prohibition against unreasonable searches and seizures requires a finding of individualized suspicion or probable cause. (5) However, over the years, the Court has carved out several exceptions to this general rule, and currently there are several limited situations where a search or seizure can be reasonable under the Court's Fourth Amendment case law even absent such individualized suspicion. These exceptions can be grouped into two categories--the "special needs doctrine," where the States pursue significant interests exceeding normal need for law enforcement, (6) and administrative searches, where there is frequently no individualized suspicion but the scope of the intrusion is correspondingly limited. (7)

In Brown v. Texas, the Supreme Court addressed the reasonableness of seizures under the Fourth Amendment in the absence of individualized suspicion. (8) In that case, two police officers cruising in a patrol car in a high-crime area of El Paso observed defendant Brown and another man in an alley. (9) The officers did not suspect any misconduct, but asked Brown to identify himself because he "looked suspicious." (10) Brown refused, so the officers arrested him. He was prosecuted for violation of a Texas statute requiring individuals to identify themselves to the police when asked. (11) The Supreme Court held that the officers violated Brown's Fourth Amendment rights "because the officers lacked any reasonable suspicion to believe that [he] was engaged in or had engaged in criminal conduct." (12)

In addition, the Brown Court set forth certain principles regarding searches or seizures conducted despite the lack of individualized suspicion. (13) Such seizures, the Court argued, are not precluded by the Fourth Amendment, but must be limited. (14) First, the "reasonableness of seizures that are less intrusive than a traditional arrest . …

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