2000 — the year in review:
Miranda’s new day in court
While no less conservative than ever, the Rehnquist Court showed last year that it was still capable of a surprise or two, especially where law enforcement was concerned. In at least two decisions handed down in 2000, the Supreme Court chose to protect individual liberties over public safety interests, prohibiting the establishment of drug-interdiction checkpoints and refusing to adopt an “automatic firearms exception” to guidelines concerning anonymous tips.
On Nov. 28 the Court ruled 6-3 in City of Indianapolis v. Edmond that erecting random roadblocks for the purpose of spotting illegal drugs violated the Fourth Amendment. Indianapolis authorities had begun operating drug-interdiction checkpoints on local roads in 1998. Six roadblocks were created between August and November of that year, with 1,161 vehicles stopped and 104 motorists arrested — 45 of them for drug-related crimes.
Writing for the majority, Justice Sandra Day O’Connor said that while the Court has upheld the right of authorities to create immigration and sobriety checkpoints, it has never approved a roadblock for the primary purpose of detecting evidence of ordinary criminal wrongdoing. Should this case rest on such a high level of generality, she said, “there would be little check on the authorities’ ability to construct roadblocks for almost any conceivable law enforcement purpose.” The program, she added, is not justified by the nature of the nation’s drug problem.
The Miranda warning is apparently here to stay, having survived a case that had perhaps the greatest potential to upend ingrained police procedure,. In Dickerson v. United States, the Court upheld its 1966 landmark decision in Miranda v. ArizonaWriting for a 7-2 majority, Chief Justice William Rehnquist said that as Miranda announced “a constitutional rule,” Congress was not free to replace its warnings with a case-by-case test of whether a confession was voluntary. The ruling invalidated a 1968 law, Section 3501 of the Federal criminal code, which superseded Miranda and allowed confessions to be admitted if they are voluntarily made.
The ruling stemmed from a case involved an accused bank robber whose volunteered confession was found admissible by a Federal appeals court in Richmond, Va.
In Florida v. J.L., the Court unanimously upheld a ruling by Florida Supreme Court which found that approving an anonymous tip which merely described a suspect’s appearance and location — even when a firearm was reported — was not enough to justify police action. The ruling stemmed from a case involving a 16-year-old who was stopped and frisked by Miami police after they received a tip that a boy in a plaid shirt was carrying a concealed weapon. A gun was found and the teenager was arrested.
During trial, however, the judge threw out evidence of the firearm on the grounds that the evidence was insufficient to support “a reasonable suspicion of criminal activity.” The decision was reversed by a state appellate court, and then reversed again by Florida highest court, which found that upholding such a search would create an unacceptable “firearms exception” to Terry v. Ohio, the Supreme Court’s landmark 1968 stop-and-frisk case.
In a victory for law enforcement, the Justices ruled 5-4 in Illinois v. Wardlow that fleeing at the sight of a police officer can be perceived as suspicious enough to warrant a stop-and-frisk search. The ruling stems from the 1995 arrest of a Chicago man, William Wardlow, who sprinted up an alley after seeing four police cars approaching. He was found to be carrying a .38-caliber handgun inside an opaque plastic bag. Wardlow had a criminal record that prohibited him from carrying a firearm.
Other appeals decided by the Court in 2000 included Bond v. United States, which held that law enforcement agents may visually inspect travelers’ luggage, but cannot squeeze or manipulate a bag to see if it contains contraband; U.S. v. Morrison, which struck down a provision of the 1994 Violence Against Women Act that gave the victims of gender-related violence the right to sue their attacker in federal court; and Florida v. Wilson, in which the Court said police may not order passengers to remain in a vehicle if there is no reason to suspect they pose a threat.