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Illinois v. Lidster

United States Supreme Court
540 U.S. 419 (2004)


Facts

On August 23, 1997 an unknown motorist hit and killed an elderly bicyclist on an Illinois highway. The accident occurred at night, and the motorist drove off without identifying himself. Exactly one week later, the local police set up a highway checkpoint for the purpose of finding out more about the previous accident. Police blocked the highway, forcing the traffic to slow down, and detained each car for about 10 to 15 seconds. Officers asked the vehicle occupants if they knew anything about the hit-and-run accident and distributed a flyer, which contained news of the accident. Lidster (defendant) was driving his minivan toward the checkpoint, but suddenly swerved his vehicle before the checkpoint, narrowly missing an officer. An officer smelled alcohol on Lidster’s breath and administered a sobriety test, after which he was arrested. Lidster was tried and convicted in state court for driving under the influence of alcohol. Lidster claimed that his seizure was unlawful under the Fourth Amendment, and the Supreme Court of Illinois agreed, relying on the decision in City of Indianapolis v. Edmond, 531 U.S. 32 (2000), which it said governed this case. The United States Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Breyer, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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