Illinois v. Batchelder

Background

An Illinois driver who was stopped for reckless, erratic driving refused a breath test. The arresting officer filed a sworn statement saying he had reasonable grounds to believe the driver was intoxicated and listed brief observations. A trial judge found the affidavit insufficient and the state court of appeals agreed, saying the affidavit did not provide the underlying circumstances needed to show intoxication. The State appealed to the Supreme Court.

Reasoning

The Court asked whether the Constitution requires an arresting officer to list specific, concrete facts in an affidavit before the State can seek suspension of a driver’s license. Relying on earlier cases that balance a person’s interest in keeping property against the risk of error and the government’s interest in public safety, the Court concluded that a pre-suspension hearing and the statutory procedures provide enough process. The Court therefore held that the Constitution does not demand detailed evidentiary recitations in these affidavits and reversed the appellate court’s ruling.

Real world impact

Practically, Illinois officers may rely on general statements that they had reasonable cause to believe a driver was intoxicated when seeking license suspension, and drivers still retain the statutory right to a hearing before suspension. The Supreme Court granted certiorari, reversed the appellate decision, and remanded for further proceedings consistent with the opinion.

Dissents or concurrances

Justice Stevens, joined by Justices Brennan and Marshall, dissented from the Court’s summary disposition, arguing the case was poorly presented and that counsel should have been appointed to represent the losing party in this Court.