holding that while suspicionless stops at a highway checkpoint may be constitutional under the Fourth Amendment when "designed primarily to serve purposes closely related to the problems of policing the border or the necessity of ensuring roadway safety," highway stops that lack "some measure of individualized suspicion" and “whose primary purpose [is] to detect evidence of ordinary criminal wrongdoing” contravene the Fourth Amendment
How later courts described this case
- holding that while suspicionless stops at a highway checkpoint may be constitutional under the Fourth Amendment when "designed primarily to serve purposes closely related to the problems of policing the border or the necessity of ensuring roadway safety," highway stops that lack "some measure of individualized suspicion" and “whose primary purpose [is] to detect evidence of ordinary criminal wrongdoing” contravene the Fourth Amendment
- stating that ”[t]he fact that officers walk a narcotics-detection dog around the exterior of each car at the Indianapolis checkpoints does not transform the seizure into a search.... [A]n exterior sniff of an automobile does not require entry into the car and is not designed to disclose any information other than the presence or absence of narcotics”
- explaining that the border search line of cases and the previous traffic stop case, Michigan Dept. of State Police v. Sitz, 496 U.S. 444, 110 S.Ct. 2481, 110 L.Ed.2d 412 (1990), were special needs cases because they involved sus-picionless search programs "whose primary purpose was [not] to detect evidence of ordinary criminal wrongdoing”
- finding unconstitutional a checkpoint with a primary purpose of interdicting illegal narcotics and stating that “[w]ithout drawing the line at roadblocks designed primarily to serve the general interest in crime control, the Fourth Amendment would do little to prevent such intrusions from becoming a routine part of American life”
Written by the judges who cited it.
Later courts went against this
Reported overruled implicitly by Ferguson v. City of Charleston, 532 U.S. 67 (2001) — not on the Supreme Court's list
532 U.S. 67, 121 S.Ct. 1281, 149 L.Ed.2d 205 (2001) effectively overruled Rise. In Edmond,
Questioned by In re D.L.C., 2003 Tex. App. LEXIS 10619 (2003)
Although Edmond and Ferguson have cast doubt on the continued viability of the pure balancing test analysis employed by the vast majority of courts addressing the constitutionality of statutory DNA databanks, we note that the United States Supreme Court has nonetheless denied certiorari in many of these cases.
Distinguished
Distinguished by Nicholas v. Goord, 430 F.3d 652 (2005)
Defendants also contend that the searches conducted in Ferguson and Edmond are distinguishable from the search at issue in this case, and therefore those cases do not apply.
Distinguished by State v. Raines, 383 Md. 1 (2004)
Additionally, both Edmond and Ferguson are distinguishable on their facts from the DNA collection context for two reasons.
The opinion
Justice Thomas,
dissenting.
Taken together, our decisions in Michigan Dept. of State Police v. Sitz, 496 U. S. 444 (1990), and United States v. Martinez-Fuerte, 428 U. S. 643 (1976), stand for the proposition that suspicionless roadblock seizures are constitutionally permissible if conducted according to a plan that limits the discretion of the officers conducting the stops. I am not convinced that Sitz and Martinez-Fuerte were correctly decided. Indeed, I rather doubt that the Framers of the Fourth Amendment would have considered “reasonable” a program of indiscriminate stops of individuals not suspected of wrongdoing.
Respondents of Sitz and Martinez-Fuerte , and I am reluctant to consider such a step without the benefit of briefing and argument. For the reasons given by The Chief Justice, I believe that those cases compel upholding the program at issue here. I, therefore, join his opinion.