United States v. Sharpe
1985 United States Supreme Court case / From Wikipedia, the free encyclopedia
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United States v. Sharpe, 470 U.S. 675 (1985), was a legal case in which the Supreme Court of the United States clarified how long police are permitted to stop vehicles as part of an investigatory stop before it violates the Fourth Amendment to the U.S. Constitution.
United States v. Sharpe | |
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Argued November 27, 1984 Decided March 20, 1985 | |
Full case name | United States v. William Harris Sharpe and Donald Davis Savage |
Citations | 470 U.S. 675 (more) 105 S. Ct. 1568 84 L. Ed. 2d 605 |
Argument | Oral argument |
Case history | |
Prior | |
Court membership | |
| |
Case opinions | |
Majority | Burger, joined by White, Blackmun, Powell, Rehnquist, O'Connor |
Concurrence | Blackmun |
Concurrence | Marshall |
Dissent | Brennan |
Dissent | Stevens |
Laws applied | |
U.S. Const. amend. IV |
On June 9, 1978, two cars, a Pontiac Bonneville driven by William Sharpe and a pickup truck with a camper driven by Donald Savage, arose the suspicion of an agent with the Drug Enforcement Administration (DEA). When the agent tried to stop both vehicles for an investigative stop, the vehicles split up. The agent stopped the Pontiac while another agent stopped the pickup truck further down the road. The agent kept Sharpe stopped for about 20 minutes while the other officers interrogated Savage. After officers determined Savage had broken the law, the agent arrested Sharpe ten minutes later, 30 minutes after the initial stop.
Sharpe accused the agent of violating the Fourth Amendment's prohibition of "unreasonable search and seizure", arguing that the stop was unduly prolonged prior to his arrest. On appeal to the U.S. Supreme Court, a seven-justice majority determined the twenty minute stop in this case was legal. However, the Court declined to adopt a bright line rule, deciding instead that "common sense and ordinary human experience must govern over rigid criteria".[1] The Court announced that the rule for determining whether a detention is too long will depend on whether the police "diligently pursued" an investigation to quickly confirm or dispel their suspicions.[1] The Court clarified that judges should avoid "unrealistic second-guessing" of police and should take into account "swiftly developing situation[s]."[1] Sharpe has been frequently cited, and is the framework used to challenge unduly prolonged police stops in thousands of criminal cases.