United States v. Martinez-Fuerte
Encyclopedia
United States v. Martinez-Fuerte, was a decision of the United States Supreme Court
that allowed the United States Border Patrol
to set up permanent or fixed checkpoints on public highways leading to or away from the Mexican border, and that these checkpoints are not a violation of the Fourth Amendment
.
. They traveled north and were stopped at a permanent checkpoint on Interstate 5
between Oceanside
and San Clemente
, then questioned. The two passengers admitted their status and the defendant was charged with two counts of illegally transporting aliens. He moved to have the evidence suppressed, on the grounds that the checkpoint stop had violated the 4th Amendment. The motion was denied and he was convicted of both counts.
, but rather were consistent with the amendment. They went on to say that it would be impracticable for the officers to seek warrants for every vehicle searched and that to do so would eliminate any deterrent towards smuggling and illegal immigration. The court felt that any intrusion to motorists was a minimal one and that the government and public interest outweighed the constitutional rights of the individual.
The court also ruled that the stops were Constitutional even if largely based on apparent Mexican ancestry.
However the court added that restrictions still exist: "We have held that checkpoint searches are constitutional only if justified by consent or probable cause to search" (though the court did hold that the probable cause bar was low for permanent checkpoints with limited impact on motorists). The Court also held, "our holding today is limited to the type of stops described in this opinion. -[A]ny further detention...must be based on consent or probable cause. Our prior cases have limited significantly the reach of this congressional authorization, requiring probable cause for any vehicle search in the interior and reasonable suspicion for inquiry stops by roving patrols [as opposed to permanent checkpoints]." 428 U.S. 543, 567 (1976).
wrote in his dissent that the decision marks a radical new intrusion on citizens' rights, and that it "empties the reasonableness requirement of the Amendment". He also says:
"The scheme of the Fourth Amendment becomes meaningful only when it is assured that at some point the conduct of those charged with enforcing the laws can be subjected to the more detached, neutral scrutiny of a judge who must evaluate the reasonableness of a particular search or seizure in light of the particular circumstances. And in making that assessment it is imperative that the facts be judged against an objective standard . . . . Anything less would invite intrusions upon constitutionally guaranteed rights based on nothing more substantial than inarticulate hunches, a result this Court has consistently refused to sanction."
Part of Justice Brennan's complaint was that this decision was the ninth that had ruled against Fourth Amendment protections that term.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
that allowed the United States Border Patrol
United States Border Patrol
The United States Border Patrol is a federal law enforcement agency within U.S. Customs and Border Protection , a component of the Department of Homeland Security . It is an agency in the Department of Homeland Security that enforces laws and regulations for the admission of foreign-born persons to...
to set up permanent or fixed checkpoints on public highways leading to or away from the Mexican border, and that these checkpoints are not a violation of the Fourth Amendment
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
.
History
The defendant, Martinez-Fuerte, had agreed to transport two illegal Mexican aliens who had entered the United States through the Port of San Ysidro in San Diego, CaliforniaCalifornia
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
. They traveled north and were stopped at a permanent checkpoint on Interstate 5
Interstate 5
Interstate 5 is the main Interstate Highway on the West Coast of the United States, running largely parallel to the Pacific Ocean coastline from Canada to Mexico . It serves some of the largest cities on the U.S...
between Oceanside
Oceanside, California
-2010:The 2010 United States Census reported that Oceanside had a population of 167,086. The population density was 3,961.8 people per square mile...
and San Clemente
San Clemente, California
San Clemente is a city in Orange County, California. The population was 63,522 at the 2010 census. Located on the California Coast, midway between Los Angeles and San Diego at the southern tip of the county, it is known for its ocean, hill, and mountain views, a pleasant climate and its Spanish...
, then questioned. The two passengers admitted their status and the defendant was charged with two counts of illegally transporting aliens. He moved to have the evidence suppressed, on the grounds that the checkpoint stop had violated the 4th Amendment. The motion was denied and he was convicted of both counts.
Opinion
The court ruled 7 to 2 that the internal checkpoints were not a violation of the Fourth AmendmentFourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
, but rather were consistent with the amendment. They went on to say that it would be impracticable for the officers to seek warrants for every vehicle searched and that to do so would eliminate any deterrent towards smuggling and illegal immigration. The court felt that any intrusion to motorists was a minimal one and that the government and public interest outweighed the constitutional rights of the individual.
The court also ruled that the stops were Constitutional even if largely based on apparent Mexican ancestry.
However the court added that restrictions still exist: "We have held that checkpoint searches are constitutional only if justified by consent or probable cause to search" (though the court did hold that the probable cause bar was low for permanent checkpoints with limited impact on motorists). The Court also held, "our holding today is limited to the type of stops described in this opinion. -[A]ny further detention...must be based on consent or probable cause. Our prior cases have limited significantly the reach of this congressional authorization, requiring probable cause for any vehicle search in the interior and reasonable suspicion for inquiry stops by roving patrols [as opposed to permanent checkpoints]." 428 U.S. 543, 567 (1976).
Dissent
Justice William BrennanWilliam J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
wrote in his dissent that the decision marks a radical new intrusion on citizens' rights, and that it "empties the reasonableness requirement of the Amendment". He also says:
"The scheme of the Fourth Amendment becomes meaningful only when it is assured that at some point the conduct of those charged with enforcing the laws can be subjected to the more detached, neutral scrutiny of a judge who must evaluate the reasonableness of a particular search or seizure in light of the particular circumstances. And in making that assessment it is imperative that the facts be judged against an objective standard . . . . Anything less would invite intrusions upon constitutionally guaranteed rights based on nothing more substantial than inarticulate hunches, a result this Court has consistently refused to sanction."
Part of Justice Brennan's complaint was that this decision was the ninth that had ruled against Fourth Amendment protections that term.