Facts
- Plainclothes vice-squad officers in an unmarked car observed a Nissan Pathfinder with temporary tags stopped at a stop sign for an unusually long time in an area associated with drug activity.
- As officers moved to approach, the vehicle turned without signaling and accelerated at an unreasonable speed.
- Officers stopped the vehicle at a red light based on observed traffic violations.
- An officer approaching the driver’s window immediately saw two large plastic bags appearing to contain crack cocaine in Whren’s hands; additional drugs were recovered.
- Whren and Brown were charged and convicted of federal drug offenses, including violations of 21 U.S.C. §§ 844(a) and 860(a).
- Defendants moved to suppress, arguing the traffic stop was a pretext to investigate drugs and lacked proper Fourth Amendment justification; the motion was denied.
Issues
- Whether the Fourth Amendment is violated when officers stop a vehicle for a traffic infraction as a pretext to investigate other suspected criminal activity, where there is objective probable cause for the traffic violation.
- Whether Fourth Amendment reasonableness depends on officers’ subjective motives or on whether a “reasonable officer” would have made the stop in ordinary practice.
Decision
- The Supreme Court affirmed the judgment upholding the convictions.
- A traffic stop is reasonable under the Fourth Amendment when officers have probable cause to believe a traffic law has been violated.
- Officers’ subjective motivations for making the stop do not affect the Fourth Amendment analysis.
- The Court rejected a test that would ask whether a reasonable officer, following typical police practices, would have made the stop for the traffic violation.
Legal Principles
- “Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis.”
- The temporary detention of a motorist is reasonable when supported by probable cause to believe a traffic violation occurred, even if officers also sought to investigate unrelated suspected crimes.
- Fourth Amendment reasonableness is assessed by objective circumstances, not by inquiry into local enforcement norms or officer-specific motivations.
- Claims of racially selective enforcement are addressed, if at all, through equal protection doctrine rather than by redefining Fourth Amendment reasonableness when objective probable cause exists.
Conclusion
A vehicle stop supported by objective probable cause for a traffic violation is constitutionally reasonable under the Fourth Amendment even when officers use the stop as a pretext to investigate other suspected criminal activity; challenges based on discriminatory enforcement sound in equal protection, not Fourth Amendment intent analysis.