People v. Ingle, 36 N.Y.2d 413 (1975)
A police officer may stop a single automobile for a routine traffic check only when the officer reasonably suspects a violation of the Vehicle and Traffic Law, or when conducted as part of a nonarbitrary, nondiscriminatory, uniform procedure, like a roadblock.
Summary
The New York Court of Appeals addressed the legality of vehicle stops for routine traffic checks. A state trooper stopped the defendant’s vintage 1949 Ford, which appeared to be in excellent condition, for a routine check, despite the absence of any observed traffic violations or suspicion of wrongdoing. The stop led to the discovery of marijuana and related paraphernalia. The Court held that stopping a single vehicle for a routine traffic check is unlawful unless there is reasonable suspicion of a violation or the stop is part of a non-arbitrary, uniform procedure, such as a roadblock. Because the stop was arbitrary, the evidence was suppressed.
Facts
On August 25, 1972, a state trooper stopped the defendant, Ingle, who was driving his well-maintained 1949 Ford on Route 96A. Ingle was not violating any traffic laws, and the trooper had no prior information about Ingle or his vehicle. The trooper initiated the stop solely to conduct a “routine traffic check.” After Ingle produced his license and registration, the trooper noticed a small wire screen and, upon consent, examined it. The trooper then detected the odor of marijuana, which led to a search of the vehicle and the discovery of marijuana and drug paraphernalia.
Procedural History
Ingle was indicted for criminal possession of a dangerous drug. His motion to suppress the evidence obtained during the traffic stop was denied. He pleaded guilty to a reduced charge after the denial of his motion. The Appellate Division affirmed the conviction. Ingle then appealed to the New York Court of Appeals.
Issue(s)
Whether a police officer may stop an automobile, arbitrarily chosen from the stream of traffic on a public highway, solely to examine the motorist’s license and registration, or to inspect the vehicle for possible equipment violations, in the absence of reasonable suspicion or a systematic procedure.
Holding
No, because stopping a single vehicle for a routine traffic check is an unreasonable seizure under the Fourth Amendment unless the officer has a reasonable suspicion of a violation of the Vehicle and Traffic Law or the stop is conducted as part of a nonarbitrary, nondiscriminatory, uniform procedure.
Court’s Reasoning
The Court reasoned that stopping an automobile constitutes a seizure under the Fourth Amendment. The Court balanced the state’s interest in highway safety against an individual’s right to freedom of movement. It held that an arbitrary stop of a single vehicle is impermissible without reasonable suspicion of a traffic violation. The Court stated that “an arbitrary stop of a single automobile for a purportedly ‘routine traffic check’ is impermissible unless the police officer reasonably suspects a violation of the Vehicle and Traffic Law.” The court emphasized that stops must not be the product of “mere whim, caprice, or idle curiosity” but rather be based upon “specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant [the] intrusion.” The Court acknowledged that nonarbitrary, uniform stops, such as those at roadblocks or checkpoints, are permissible because they serve the state’s interest in highway safety without granting undue discretion to individual officers. Because the trooper’s stop of Ingle was arbitrary and not based on any suspicion or systematic procedure, the evidence obtained from the stop should have been suppressed. The court distinguished between the stop and inspection of a vehicle, and a subsequent search, noting that different rules apply to searches.