Application at Checkpoints
*Initial Stop: Most checkpoints (DUI, immigration) are "suspicionless," meaning they don't require probable cause to stop you.
*Observation: While checking licenses or performing administrative tasks, officers can look into your vehicle. If they see something like an open alcohol container or illegal drugs, that "plain sight" observation creates probable cause.
*Scope of Search: Once probable cause is established via plain view, the Automobile Exception allows the officer to search the rest of the vehicle for further evidence.
*Limits: Officers cannot move jackets, open bags, or lean deeply into the car just to get a better look unless they already have probable cause. For example, in Arizona v. Hicks, moving a stereo to see its serial number was ruled an unconstitutional search.
Key Legal Precedents
--Horton v. California (1990): Clarified that the discovery of evidence does not need to be "inadvertent" to be valid under plain view.
--Michigan Dept. of State Police v. Sitz (1990): Upheld the constitutionality of sobriety checkpoints as a public safety measure.
--City of Indianapolis v. Edmond (2000): Ruled that checkpoints primarily for "general crime control" (like drug sweeps) are unconstitutional.
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