Criminal Justice
Read one of the following cases carefully. Excerpts of both of those cases are contained in the materials for this module, but I strongly encourage you to read the full U.S. Supreme Court decision of the case you choose to cover.
1- Illinois v. Caballes: https://supreme.justia.com/cases/federal/us/543/405/ (Links to an external site.)
2- Kyllo v. the U.S.: https://supreme.justia.com/cases/federal/us/533/27/ (Links to an external site.)
Note that you may have to access multiple tabs to get the complete decision. Though not necessary to complete the assignment, also note that the links below give you access to the audio of the oral arguments before the Supreme Court, if you are interested.
Write a case brief on your selected case using the Case Brief format
I have attached the case brief format in the additional materials. THANKS
ANSWER
Case Brief: Illinois VS Caballes
Case Citation: The state of Illinois is the petitioner, and Roy L. Caballes is the respondent. The case was on docket number 03-923. Decided by the Rehnquist Court. The case was heard in the supreme court of Illinois. The case was decided on January 24th 2005.
Facts of the Case: an Illinois state troop stopped Roy Caballes for speeding on a highway. The trooper radioed the police dispatcher to report the stop, and a second trooper overheard the transmission (Bekiares, 2005). The trooper presumably did not have any information on Caballes, but they arrived at the scene with a narcotics detection dog. As the first trooper was writing the warning ticket, the second trooper walked the dog around the car, and the dog alerted them to the trunk. The trunk was searched, and there was Marijuana. Caballes was arrested for possession of Marijuana.
An Illinois trial court denied the motion by Caballes to suppress the seized evidence and quash the arrest. They concluded that; 1) the police had not prolonged the stop unnecessarily 2)the dog alert was enough to provide probable cause to conduct a search. The appellate court of Illinois affirmed this. However, the supreme court of Illinois reversed this, stating that the canine sniffing was performed without specific and articulate facts to suggest drug activity. Their use of a dog had unjustifiably enlarged the scope of a routine traffic stop into a drug investigation.
Issues: Did the dog’s sniffing done in the exterior of a car done during a valid traffic stop violate the federal constitution fourth amendment?
Procedural History: An Illinois trial court denied the motion by Caballes to suppress the seized evidence and quash the arrest. They concluded that; 1) the police had not prolonged the stop unnecessarily 2)the dog alert was enough to provide probable cause to conduct a search. This was affirmed by the appellate court of Illinois (Johnston, 2005). However, the supreme court of Illinois reversed this, stating that the canine sniffing was performed without specific and articulate facts to suggest drug activity. Their use of a dog had unjustifiably enlarged the scope of a routine traffic stop into a drug investigation.
Decisions: In the case proceedings, the judges carefully reviewed the details of the conversations between the officers and the respondent. When he was stopped on the highway, the initial seizure of the respondent was probable cause and was therefore lawful (Blair, 2005). It is, however, clear that lawful inception can violate the fourth amendment. The Supreme Court held that the traffic stop characterized the dog sniff as the cause rather than the consequence of a constitutional violation. The change from a traffic stop to a drug investigation was unlawful. The dog sniff did not infringe the respondent’s privacy, and therefore his first amendment rights were not violated.
Reasoning: the Supreme Court held that the fourth amendment is not violated when the use of a drug-sniffing dog during a traffic stop does not unnecessarily prolong the stop (Dery, 2005). This decision was reached after close reviews of the conversation between the respondent and the trooper, and after the realization, the dogs only sniffed the exterior of the car.
Separate Opinions: the Supreme Court and the Illinois trial court had different opinions on the dog sniff. The Supreme Court introduced the aspect of the dog enlarged the scope of the routine traffic stop into a drug investigation.
Impact on Discretion: the court’s decision warranted the police unreasonable stops and searches as they do not infringe on the first amendment. The court’s decision also benefits the citizens as they are protected from drug traffickers as the police can search a vehicle that they suspect to be ferrying drugs.
References
Bekiares, J. A. (2005). Constitutional Law: Ratifying Suspicionless Canine Sniffs: Dog Days on the Highways-Illinois v. Caballes. Fla. L. Rev., 57, 963.
Blair, C. (2005). Illinois v. Caballes: Love Affair with a Drug-Sniffing Dog. Tulsa L. Rev., 41, 179.
Dery III, G. M. (2005). Who Let the Dogs Out-The Supreme Court Did in Illinois v. Caballes by Placing Absolute Faith in Canine Sniffs. Rutgers L. Rev., 58, 377.
Johnston, J. B. (2005). Drugs, Dogs, and the Fourth Amendment: An Analysis of Justice Stevens’ Opinion in Illinois v. Caballes. QLR, 24, 659.
