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

NCJ Number
The Journal of Criminal Law and Criminology Volume: 93 Issue: 1 Dated: Fall 2002 Pages: 227-257
Ann Mulligan
Matthew Burke
Date Published
31 pages
This paper presents arguments in the Supreme Court’s decision in City of Indianapolis v. Edmond (2001) that drug interdiction checkpoints are unconstitutional violations of the fourth amendment (the prohibition against unreasonable searches and seizures).
The fourth amendment prohibits unreasonable searches and seizures of individuals; and requires a finding of individualized suspicion or probable cause. However, over the years several exceptions have occurred. In 1998, the City of Indianapolis developed a system of vehicle checkpoints designed to interdict illegal narcotics. In 2001, the Supreme Court ruled on the constitutionality of the drug interdiction program. It held that the drug interdiction checkpoints were unconstitutional violations of the fourth amendment because the primary purpose of the checkpoints was general crime control. However, in previous roadblock cases of the United States v. Martinez-Fuerte and Michigan Department of State Police v. Sitz, it was clearly established that roadblocks in certain situations are constitutional. This paper argues that the decision in City of Indianapolis was incorrect. The Court adopted reasoning different from its previous analyses of roadblock cases. The Court’s promise of greater fourth amendment protection is deceptive since the same types of seizures might be upheld if they are conducted in a program with a different stated primary purpose. Challenges to roadblock cases will increase and lower courts will lack clear guidance about how to approach them and how to evaluate the constitutionality of roadblocks under the fourth amendment.