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Edwards v. State

6/19/2001

ted States v. Martinez-Fuerte, 428 U.S. 543, 558 (1976).


. In Prouse, the Court analyzed the issue of the Fourth Amendment reasonableness of stops to check for a license or registration "by balancing its intrusion on the individual's Fourth Amendment interests against its promotion of legitimate governmental interests." Prouse, 440 U.S. at 654. This balancing requirement originated in Camara v. Municipal Court, 387 U.S. 523, 539 (1967); 4 Wayne R. LaFave, Search and Seizure § 10.8(a) (3d ed.1996).


. There are three requirements under Camara to validate a particular law enforcement practice involving a stop and limited detention: (1) existence of a strong public interest in maximizing success in combating the problem at hand; (2) an inability to achieve adequate result by relying on probable cause determinations; and (3) the "relatively limited invasion of the * * * citizen's privacy" involved in the procedure in question. Camara, 387 U.S. at 537. "Applying the previously discussed Camara standards, it would seem clear that the required stops at these stations for the purpose of weighing are reasonable under the Fourth Amendment." 4 LaFave, Search and Seizure § 10.8(c).


. In Edmond, the Supreme Court referred to Camara as a case supporting administrative inspections. Edmond, 121 S.Ct. at 452. Similar factors have been applied to temporary law enforcement stops of individuals. Brown v. Texas, 443 U.S. 47, 50-51 (1979) (seizures involve "a weighing of the gravity of the public concerns served by the seizure, the degree to which the seizure advances the public interest, and the severity of the interference with individual liberty").


. Requiring truckers to stop at this weigh station was valid.


2. Random inspection


. Once the seizure occurred, the evidence supported that the officers randomly selected Edwards's truck for an additional, "walk-around" inspection. There was at least a suggestion in Prouse that weigh station stops followed by additional inspections could be justified. As mentioned above, the Court did not intend to "cast doubt on the permissibility of roadside truck weigh-stations and inspection checkpoints, at which some vehicles may be subject to further detention for safety and regulatory inspection than are others." Prouse, 440 U.S. at 663 n. 26.


. We repeat the relevant facts in our case. The officers randomly chose Edwards for an additional obligation. It was to pull his truck to the side for a walk-around inspection. After Edwards did so, he walked into the inspection station. There he was questioned by two officers, Matthew Lott and Tex Jones. Lott told Edwards that he wanted to see his bill of lading, truck registration and his driver's license. Edwards returned to the truck to get it, acting angry and agitated according to Lott. After Lott reviewed the paperwork, he found it to be in order. Edwards was then informed that the officers would begin a walk-around inspection of the vehicle. That is when the vehicle identification number would be compared to the "cab card," the safety of the tires checked, and the existence and condition of mud flaps and load-restraining straps on flatbed trailers would be determined.


. For the substantive answer to whether random selection for these inspections is proper, we return to the Camara factors that are referenced in Prouse. Prouse, 440 U.S. at 654.


. First, there is a strong public interest in assuring that the large commercial vehicles are meeting minimal safety standards such as the condition of their tires, mud flaps, straps holding down loads, and other matters being inspected as described by the testimony at trial. Examining the

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