City of Indianapolis v. Edmond

Supreme Court of the United States · 2000 · Criminal Procedure

531 U.S. 32 (2000)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentSuspicionless Checkpointscheckpointroadblocksuspicionless seizureindividualized suspicionprimary purpose

Facts

In 1998 Indianapolis operated six vehicle checkpoints on city roads to interdict unlawful drugs, stopping 1,161 vehicles and making 104 arrests, 55 of them drug-related. At each checkpoint officers stopped a predetermined number of vehicles, informed drivers they were at a drug checkpoint, requested license and registration, looked for signs of impairment, visually inspected the vehicle from outside, and had a narcotics-detection dog walk around the exterior of each car. Officers had no discretion to stop cars out of sequence, searches required consent or the proper level of particularized suspicion, and stops without further cause were to last no more than five minutes, usually two to three minutes. Signs announced the checkpoints as narcotics checkpoints, and the parties stipulated that the checkpoints were operated in an effort to interdict unlawful drugs.

Issue

Whether the Fourth Amendment permits suspicionless highway checkpoints whose primary purpose is the discovery and interdiction of illegal narcotics. More specifically, the question was whether Indianapolis could stop motorists without individualized suspicion at checkpoints designed primarily to uncover evidence of ordinary criminal wrongdoing.

Rule

A search or seizure is ordinarily unreasonable absent individualized suspicion, and only limited exceptions permit suspicionless checkpoint seizures. A checkpoint program is unconstitutional when its primary purpose is to uncover evidence of ordinary criminal wrongdoing or to advance the general interest in crime control; by contrast, previously approved checkpoints were tied primarily to border control or roadway safety. In evaluating such programs, courts may examine purpose at the programmatic level, not the subjective motives of individual officers.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The police department in Dayton, Ohio sets up weekend checkpoints at major intersections. Every fifth car is stopped for about two minutes, and officers ask for license and registration while a trained dog walks around the exterior of each vehicle. Internal directives, public notices, and checkpoint signs all describe the operation as a program to find illegal guns and narcotics in circulating vehicles.

A driver challenges the checkpoint under the Fourth Amendment. Which is the strongest argument for the driver?

Explanation. Under the majority rule, courts examine the checkpoint's primary purpose at the programmatic level. A suspicionless vehicle checkpoint violates the Fourth Amendment when its primary purpose is the general interest in crime control or uncovering evidence of ordinary criminal wrongdoing. Neutral procedures and brief duration do not save a checkpoint whose stated design is drug or gun interdiction, and the Court specifically treated the defect as purpose-based rather than turning on whether the dog sniff was a search.