Summary of Delaware v. Prouse

Citation: 440 U.S. 648

Relevant Facts: In Delaware, a policeman stopped William Prouse’s vehicle in order to make a routine check of his driver’s license and registration.  The officer’s decision to initiate the traffic stop was not based upon any observable traffic violation or suspicious conduct by Prouse.  After initiating the stop, the officer found marijuana in the vehicle.  The marijuana was ultimately used as evidence in the successful indictment against Prouse.

Issues: The legal question presented was whether the officer’s search of Prouse’s vehicle violated his constitutional rights against unreasonable search and seizure pursuant to the Fourth Amendment.

Holding: The Court found that Prouse’s constitutional rights had in fact been violated.

Reasoning: The Court reasoned that the state’s interests concerning discretionary traffic stops (spot checks) did not outweigh the privacy interests of travelers (drivers).  The Court ruled that random checks did not greatly improve road safety, and therefore did not constitute a prevailing state interest that would outweigh citizens’ privacy interests.  The Court finally reasoned that officers must have probable cause for such searches or else it would blur the limitations imposed upon the government, which is the purpose of the Fourth Amendment.

Conclusion: This case was significant because the Supreme Court ruled that law enforcement must have some modicum of probable cause in order to stop a vehicle; that there are limitations to searching vehicles and seizing evidence, particularly when borne out of stops not based on probable cause.