The Court…carefully protects from the reach of its decision other less intrusive spot checks "that do not involve the unconstrained exercise of discretion." Thus, the permissibility of a particular law enforcement practice is judged by balancing its intrusion on the individual's Fourth Amendment interests against its promotion of legitimate governmental interests.

This Court has jurisdiction in this case even though the Delaware Supreme Court held that the stop at issue not only violated the Federal Constitution but also was impermissible under the Delaware Constitution. Furthermore, in Delaware, as elsewhere, vehicles must carry and display current license plates, which themselves evidence that the vehicle is properly registered; and, under Delaware law, to qualify for annual registration a vehicle must pass the annual safety inspection and be properly insured. I necessarily assume that the Court's reservation also includes other not purely random stops (such as every 10th car to pass a given point) that equate with, but are less intrusive than, a 100% roadblock stop. If you are interested, please contact us at, Have you written case briefs that you want to share with our community? At a hearing on respondent's motion to suppress the marihuana seized as a result of the stop, the patrolman testified that prior to stopping the vehicle he had observed neither traffic or equipment violations nor any suspicious activity, and that he made the stop only in order to check the driver's license and registration. In this case, however, the State of Delaware urges that patrol officers be subject to no constraints in deciding which automobiles shall be stopped for a license and registration check because the State's interest in discretionary spot checks as a means of ensuring the safety of its roadways outweighs the resulting intrusion on the privacy and security of the persons detained. Accordingly, we hold that except in those situations in which there is at least articulable and reasonable suspicion that a motorist is unlicensed or that an automobile is not registered, or that either the vehicle or an occupant is otherwise subject to seizure for violation of law, stopping an automobile and detaining the driver in order to check his driver's license and the registration of the automobile are unreasonable under the Fourth Amendment. The Delaware Supreme Court affirmed…We granted certiorari to resolve the conflict between this decision, which is in accord with decisions in five other jurisdictions, and the contrary determination in six jurisdictions that the Fourth Amendment does not prohibit the kind of automobile stop that occurred here. Get Delaware v. Prouse, 440 U.S. 648 (1979), United States Supreme Court, case facts, key issues, and holdings and reasonings online today. The patrolman was not acting pursuant to any standards, guidelines, or procedures pertaining to document spot checks, promulgated by either his department or the State Attorney General. All rights reserved. Get compensated for. At 7:20 p. m. on November 30, 1976, a New Castle County, Del., patrolman in a police cruiser stopped the automobile occupied by respondent. After initiating the stop, the officer found marijuana in the vehicle. The foremost method of enforcing traffic and vehicle safety regulations, it must be recalled, is acting upon observed violations…It seems common sense that the percentage of all drivers on the road who are driving without a license is very small and that the number of licensed drivers who will be stopped in order to find one unlicensed operator will be large indeed. Many violations of minimum vehicle-safety requirements are observable, and something can be done about them by the observing officer, directly and immediately. On the record before us, that question must be answered in the negative. The marijuana was ultimately used as evidence in the successful indictment against Prouse. The Court finally reasoned that officers must have probable cause for such searches or else it would blur the limitations imposed upon the government, which is the purpose of the Fourth Amendment. 2d 1359, affirmed. Reasoning: The Court reasoned that the state’s interests concerning discretionary traffic stops (spot checks) did not outweigh the privacy interests of travelers (drivers). Almeida-Sanchez v. United States, 413 U.S. 266, 270 (1973); Camara v. Municipal Court, 387 U.S., at 532-533. Argued January 17, 1979 Decided March 27, 1979.

382 A. Unquestionably, these provisions, properly administered, are essential elements in a highway safety program Furthermore, we note that the State of Delaware requires a minimum amount of insurance coverage as a condition to automobile registration, implementing its legitimate interest in seeing to it that its citizens have protection when involved in a motor vehicle accident. The roadblock stop for all traffic is given as an example. The contribution to highway safety made by discretionary stops selected from among drivers generally will therefore be marginal at best. Byron R. White: This comes here on writ of certiorari to the Supreme Court of Delaware. Decided March 27, 1979. Relevant Facts: In Delaware, a policeman stopped William Prouse’s vehicle in order to make a routine check of his driver’s license and registration. Automobile licenses are issued periodically to evidence that the drivers holding them are sufficiently familiar with the rules of the road and are physically qualified to operate a motor vehicle. The Court arrives at its conclusion without the benefit of a shred of empirical data in this record suggesting that a system of random spot checks would fail to deter violators. The marginal contribution to roadway safety possibly resulting from a system of spot checks cannot justify subjecting every occupant of every vehicle on the roads to a seizure - limited in magnitude compared to other intrusions but nonetheless constitutionally cognizable - at the unbridled discretion of law enforcement officials. Holding: The Court found that Prouse’s constitutional rights had in fact been violated. The essential purpose of the proscriptions in the Fourth Amendment is to impose a standard of "reasonableness". Conclusion: This case was significant because the Supreme Court ruled that law enforcement must have some modicum of probable cause in order to stop a vehicle; that there are limitations to searching vehicles and seizing evidence, particularly when borne out of stops not based on probable cause. But a random license check of a motorist operating a vehicle on highways owned and maintained by the State is quite different from a random stop designed to uncover violations of laws that have nothing to do with motor vehicles. The facts were simple.

Un article de Wikipédia, l'encyclopédie libre, Creative Commons Attribution-ShareAlike 3.0 Unported License. The whole point of enforcing motor vehicle safety regulations is to remove from the road the unlicensed driver before he demonstrates why he is unlicensed.

When there is not probable cause to believe that a driver is violating any one of the multitude of applicable traffic and equipment regulations - or other articulable basis amounting to reasonable suspicion that the driver is unlicensed or his vehicle unregistered - we cannot conceive of any legitimate basis upon which a patrolman could decide that stopping a particular driver for a spot check would be more productive than stopping any other driver. In a situation of that type, it seems to me, the Court's balancing process, and the value factors under consideration, would be quite different. DELAWARE v. PROUSE. The reasonableness of the enforcement measure chosen by the State is tested by weighing its intrusion on the motorists' Fourth Amendment interests against its promotion of the State's legitimate interests.

The officer’s decision to initiate the traffic stop was not based upon any observable traffic violation or suspicious conduct by Prouse. The question remains, however, whether in the service of these important ends the discretionary spot check is a sufficiently productive mechanism to justify the intrusion upon Fourth Amendment interests which such stops entail. As the Court correctly points out, people are not shorn of their Fourth Amendment protection when they step from their homes onto the public sidewalks or from the sidewalks into their automobiles. Nor is the Court impressed with the deterrence rationale, finding it inconceivable that an unlicensed driver who is not deterred by the prospect of being involved in a traffic violation or other incident requiring him to produce a license would be deterred by the possibility of being subjected to a spot check.

Given the alternative mechanisms available, both those in use and those that might be adopted, we are unconvinced that the incremental contribution to highway safety of the random spot check justifies the practice under the Fourth Amendment. Summary of Delaware v. Prouse. Held: 1. Although a system of discretionary stops could conceivably be abused, the record before us contains no showing that such abuse is probable or even likely. Copyright © 2001-2012 4LawSchool.com. The question is whether it is an unreasonable seizure under the Fourth and Fourteenth Amendments to stop an automobile, being driven on a public highway, for the purpose of checking the driving license of the operator and the registration of the car, where there is neither probable cause to believe nor reasonable suspicion that the car is being driven contrary to the laws governing the operation of motor vehicles or that either the car or any of its occupants is subject to seizure or detention in connection with the violation of any other applicable law. 440 U.S. 648. And I would not regard the present case as a precedent that throws any constitutional shadow upon the necessarily somewhat individualized and perhaps largely random examinations by game wardens in the performance of their duties. Undoubtedly, many find a greater sense of security and privacy in traveling in an automobile than they do in exposing themselves by pedestrian or other modes of travel. . The registration requirement and, more pointedly, the related annual inspection requirement in Delaware are designed to keep dangerous automobiles off the road. A Delaware policeman and a policeman … Written and curated by real attorneys at Quimbee. In reaching their decision, justices depended on guidance rendered in previous decisions regarding constitutionally legal, random spot checks conducted by U.S. Border Patrol officers.