Kettle v. the State

I disagree with the majority’s conclusion in Division 2 that the roadblock satisfied constitutional requirements, and therefore respectfully dissent.

The majority holds that the trial court was authorized to conclude that the State presented adequate proof that the roadblock program, when viewed at the programmatic level, had an appropriate primary purpose other than general crime control. But that is only part of the analysis. Our courts “refer to the ‘Edmond[2\ requirement’ or the ‘appropriate primary purpose requirement’ — with ‘appropriate’ understood to mean a primary purpose that is both…