Whren v. United States
Following is the case brief for Whren v. United States, 517 U.S. 806 (1996)
Case Summary of Whren v. United States:
- Undercover officers observed Petitioners Whren and Brown in a truck.
- The driver of the truck (Brown) violated traffic laws by suddenly pulling away at an unreasonable speed.
- The officers stopped the truck and, upon approaching the truck on foot, saw plastic bags of crack cocaine in Whren’s hands. Petitioners were arrested.
- Prior to trial on drug charges, the District Court denied petitioners’ motion to suppress the drugs as discovered in violation of the Fourth Amendment. The Court of Appeals affirmed.
- The U.S. Supreme Court affirmed as well. The unanimous Court held that as long as there is probable cause to stop a vehicle for a traffic infraction, the subjective intent of the officer who stopped the car is irrelevant for Fourth Amendment purposes.
Whren v. United States Case Brief
Statement of the Facts:
Undercover officers, who were patrolling a “high drug area” in an unmarked vehicle, saw Petitioners Whren and Brown in a truck, waiting at a stop sign for an unusually long time. The officers observed petitioners’ truck suddenly turn without signaling, and speed off at an “unreasonable” speed.
The officers stopped petitioners’ truck. Upon approaching the truck, one officer saw plastic bags of crack cocaine in petitioner Whren’s hands. Petitioners were then arrested. Prior to trial, petitioners moved to suppress the drug evidence, claiming that the traffic violation was used as a pretext to search petitioners in violation of the Fourth Amendment.
Procedural History:
- The District Court denied the motion to suppress.
- The D.C. Circuit Court of Appeals affirmed.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Is an officer’s subjective intent in stopping someone for a traffic violation relevant when analyzing a Fourth Amendment issue? No.
Judgment:
The decision of the D.C. Circuit Court of Appeals is affirmed.
Rule of Law or Legal Principle Applied:
As long as a police officer had probable cause to believe a traffic violation occurred, a subsequent search does not violate the Fourth Amendment, regardless of the officer’s subjective intent in stopping the vehicle.
Reasoning:
Stopping a driver is reasonable when there is probable cause to believe that a traffic violation occurred. Court precedent forecloses any argument that an officer’s ulterior motives can invalidate police conduct that is justified by probable cause.
Petitioners’ attempt to fashion a new “reasonableness” standard for Fourth Amendment searches to avoid the use of traffic violations as a pretext to search a vehicle must be rejected. That is because police action is justified if based on probable cause.
Thus, the temporary detention of a driver based on probable cause of a traffic violation is not an unreasonable seizure under the Fourth Amendment, even if a reasonable officer would not have stopped the driver absent some other law enforcement objective.
Significance:
Whren v. United States is significant because it puts — front and center — the issue of police using traffic infractions as a reason to stop vehicles in order to discover more serious crimes, and also the dangers involved in racial profiling. While the Court acknowledges the reality of those issues, it still found that the existence of probable cause for any violation can justify a car stop.
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