Administrative searches

Question 1

Colorado v. Bertine

Answer 1

Facts
In Boulder, Colorado, on February 10, 1984, a police officer arrested Steven Lee Bertine for driving under the influence of alcohol. Following his arrest and prior to the van being towed to an impound lot, a backup officer conducted an inventory search of Bertine’s van as per local police procedures. During the search, the officer opened a closed backpack found directly behind the front seat, which contained cocaine, methaqualone tablets, cocaine paraphernalia, and cash. Subsequent to the discovery, Bertine was charged with driving under the influence, unlawful possession of cocaine with intent to distribute, and unlawful possession of methaqualone.

Issue
The key issue in this case was whether the Fourth Amendment prohibits the use of evidence found during a police inventory of Bertine’s van, particularly focusing on whether the inventory search, including the opening of a closed backpack, was permissible under the Fourth Amendment.

Holding
The Supreme Court held that the inventory search of Bertine’s van, including the opening of the closed backpack and its containers, did not violate the Fourth Amendment.

Question 2

Michigan v. Sitz

Answer 2

[W]hether a State’s use of highway sobriety checkpoints violates the Fourth and Fourteenth Amendments to the United States Constitution[?]”

The court first observed that the police department agrees there is a Fourth Amendment “seizure” when a vehicle is stopped at a checkpoint. Also, that the question becomes whether the stop is “reasonable” under the Fourth Amendment. The majority went out of its way to point out, “[a]s pursued in the lower courts, the instant action challenges only the use of sobriety checkpoints generally. We address only the initial stop of each motorist passing through a checkpoint and the associated preliminary questioning and observation by checkpoint officers.” The court found that the appropriate test to be applied is the balancing test from [Brown v. Texas], which involves “balancing the state’s interest in preventing accidents caused by drunk drivers, the effectiveness of sobriety checkpoints in achieving that goal, and the level of intrusion on an individual’s privacy caused by the checkpoints.”

Question 3

City of Indianapolis v. Edmond,

Answer 3

Facts
In August 1998, the City of Indianapolis initiated vehicle checkpoints on its roads aiming to interdict illegal narcotics. Between August and November of that year, six roadblocks were conducted, resulting in 1,161 vehicles being stopped and 104 motorists arrested, with approximately half for drug-related crimes. The checkpoints operated under specific directives, where officers would stop a predetermined number of vehicles, inform drivers of the drug checkpoint, request license and registration, and conduct an open-view examination of the vehicle from the outside. A narcotics-detection dog was also used to walk around the exterior of each stopped vehicle. The operation of these checkpoints was challenged by James Edmond and Joell Palmer, who filed a lawsuit claiming that the roadblocks violated the Fourth Amendment of the United States Constitution.

Issue
The primary issue before the Court was whether the vehicle checkpoints established by the City of Indianapolis, primarily for the purpose of detecting illegal narcotics, were constitutional under the Fourth Amendment.

Holding
The Supreme Court held that the narcotics detection checkpoints were unconstitutional under the Fourth Amendment, affirming the judgment of the Court of Appeals.

Question 4

Safford Unified School District #1 v. Redding

Answer 4

Facts
In October 2003, at Safford Middle School, Arizona, Savana Redding, a 13-year-old student, was subjected to a search by school officials. Assistant Principal Kerry Wilson had received a report that Savana was distributing prescription-strength ibuprofen and over-the-counter naproxen—both banned without prior permission—among her classmates. The initial suspicion arose after a student, Jordan, reported sick from pills claimed to have been received from another student, Marissa Glines, who, upon being searched, was found with pills and attributed them to Savana. Savana consented to a search of her backpack and outer clothing, which yielded no pills. Subsequently, she was taken to the nurse’s office, asked to remove her outer clothing, and instructed to pull out her bra and underpants, which exposed her breasts and pelvic area to some extent. No pills were found. Savana’s mother sued the school district and the involved officials for violating Savana’s Fourth Amendment rights.

Issue
The legal issue at the core of the case was whether the strip search of Savana Redding violated her Fourth Amendment rights against unreasonable searches and seizures.

Holding
The Supreme Court held that the search of Savana Redding’s underwear violated the Fourth Amendment.