Facts
- Police investigated a fatal hit-and-run in Lombard, Illinois, in which a bicyclist was killed.
- About one week later, officers set up a highway checkpoint at the same location and around the same time of night as the crash.
- Officers stopped each vehicle for about 10–15 seconds, asked whether occupants saw anything the prior weekend, and handed out a flyer requesting information.
- Robert S. Lidster approached the checkpoint, swerved, and nearly struck an officer.
- An officer smelled alcohol on Lidster’s breath; Lidster failed a sobriety test and was arrested for driving under the influence.
- Lidster was convicted in Illinois state court based on evidence obtained after the checkpoint stop.
Issues
- Whether a checkpoint that briefly stops motorists to request information about a prior hit-and-run is an unreasonable seizure under the Fourth Amendment.
- Whether such an information-seeking checkpoint is barred by the rule against suspicionless “general crime control” checkpoints.
Decision
- The Supreme Court reversed the Illinois Supreme Court and remanded.
- The Court held the checkpoint stop was a Fourth Amendment seizure but was constitutionally reasonable.
- The Court distinguished checkpoints aimed at discovering crimes by the stopped motorists from checkpoints aimed at obtaining public assistance in investigating a crime committed by others.
- Applying a reasonableness balance, the Court found: (1) the public concern was grave (a death), (2) the checkpoint was suitably targeted to obtain useful information, and (3) the interference with liberty was minimal given the brief, uniform stops.
Legal Principles
- Reasonableness under the Fourth Amendment requires balancing the public interest against the individual’s interest in freedom from arbitrary law-enforcement interference.
- A suspicionless checkpoint is not automatically unconstitutional when its primary purpose is to seek information from the public about a specific past crime, rather than to detect ordinary criminal wrongdoing by the stopped drivers.
- In information-seeking stops, individualized suspicion has limited relevance because the stop is not premised on suspicion of the stopped motorist.
- Courts assess checkpoint validity by examining the gravity of the public concern, the degree to which the checkpoint advances that concern, and the severity of the interference with personal liberty.
Conclusion
The Court upheld a brief, targeted checkpoint designed to solicit information about a fatal hit-and-run, holding that such information-seeking stops may be reasonable under the Fourth Amendment even without individualized suspicion, and are distinct from prohibited “general crime control” checkpoints.