United States v. Sokolow

Background

Andrew Sokolow, a traveler, bought two round-trip tickets in other names, paid $2,100 in cash from a roll of $20 bills, flew to Miami for 48 hours, appeared nervous, wore a black jumpsuit and gold jewelry, and checked no luggage. DEA agents encountered him at Honolulu Airport, seized him on the sidewalk, brought his bags to a narcotics dog, and later obtained a warrant that uncovered 1,063 grams of cocaine; Sokolow entered a conditional guilty plea and was indicted for drug distribution.

Reasoning

The Supreme Court considered whether the agents had enough reason to stop Sokolow. The Court rejected a rigid rule that required a single sign of ongoing criminal conduct and instead evaluated the "totality of the circumstances." Looking at the combination of cash ticket purchase, name discrepancies, short stay in a source city, nervous behavior, and lack of checked luggage, the Court concluded those facts together gave agents reasonable suspicion to detain him and reversed the Ninth Circuit decision that had overturned the stop.

Real world impact

The ruling permits law enforcement to rely on a bundle of travel and behavioral indicators, including profiles used by the DEA, when deciding to stop and briefly detain airline passengers. The decision was seen as important for federal narcotics enforcement and was remanded for further proceedings consistent with the Court's view that the stop was justified.

Dissents or concurrances

Justice Marshall, joined by Justice Brennan, dissented, arguing the facts were too weak and that mechanical reliance on drug-courier profiles risks subjecting innocent travelers to harassment and undermines Fourth Amendment protections.