United States v. Sharpe

1985-03-20

Headline: Court upholds a roughly 20-minute roadside detention when officers act diligently and a suspect’s evasive driving caused the delay, allowing police to hold suspected drug couriers briefly while investigating.

Holding: The Court ruled that a roughly 20-minute detention of a vehicle suspect was reasonable under the Fourth Amendment when officers diligently pursued a narrow investigation and the suspect’s evasive conduct contributed to the delay.

Real World Impact:

Permits short twenty-minute detentions during vehicle investigations if officers act diligently.
Supports admitting drug evidence found after such brief, diligent stops.
Signals courts will weigh suspect behavior when assessing detention length.

Topics: police stops, searches and seizures, drug trafficking, detention length

Summary

Background

On June 9, 1978, a Drug Enforcement Administration agent (Agent Cooke) followed two vehicles that looked suspicious on a coastal road. A state officer (Officer Thrasher) joined the stop. One driver pulled over; the pickup truck continued, was stopped about a half mile away, and its driver (Savage) was held while Cooke came to the scene, smelled marijuana, opened the camper, and found large bales. The two men (Sharpe and Savage) were convicted, the Court of Appeals reversed on the ground that the detentions were too long, and the case reached the Supreme Court.

Reasoning

The Supreme Court focused on whether the roughly 20-minute detention of Savage was reasonable under the Fourth Amendment as a limited investigative stop. The majority said courts must look at whether officers pursued the investigation diligently and whether the suspect’s own evasive actions contributed to delay. Because Cooke could not immediately join Thrasher, he asked for local help, checked identification, sought permission to search, stepped on the truck to test its load, and then smelled marijuana, the Court held the detention reasonable under those facts and reversed the appeals court.

Real world impact

The decision means police may detain suspected drivers for short periods longer than a few minutes when officers are actively investigating and the suspect’s conduct helps cause delay. The ruling leaves open review of how long is too long and emphasizes factual inquiry about police work and suspect behavior.

Dissents or concurrances

Justices voiced different concerns: one would have dismissed or vacated because the defendants became fugitives; another joined the result but warned that stops must remain very brief; a strong dissent argued the lengthy detentions violated established Fourth Amendment protections.