532 U.S. 769 (2001)
In November 1998, Officer Joe Taylor of the Conway, Arkansas, Police Department stopped respondent Sullivan for speeding and for having an improperly tinted windshield.1 Taylor approached Sullivan’s vehicle, explained the reason for the stop, and requested Sullivan’s license, registration, and insurance documentation. Upon seeing Sullivan’s license, Taylor realized that he was aware of intelligence on Sullivan regarding narcotics. When Sullivan opened his car door in an unsuccessful attempt to locate his registration and insurance papers, Taylor noticed a rusted roofing hatchet on the car’s floorboard. Taylor then arrested Sullivan for speeding, driving without his registration and insurance documentation, carrying a weapon, and improper window tinting.2
After another officer arrived and placed Sullivan in his squad car, Officer Taylor conducted an inventory search of Sullivan’s vehicle pursuant to the Conway Police Department’s Vehicle Inventory Policy. Under the vehicle’s armrest, Taylor discovered a bag containing a substance that appeared to him to be methamphetamine as well as numerous items of suspected drug paraphernalia. As a result of the detention and search, Sullivan was charged with state-law drug offenses, unlawful possession of a weapon, and speeding.3
Sullivan moved to suppress the evidence seized from his vehicle on the basis that his arrest was merely a pretext and sham to search him. The trial court granted the suppression motion. On the State’s interlocutory appeal, the Arkansas Supreme Court affirmed. The State petitioned for rehearing, contending that the court had erred by taking into account Officer Taylor’s subjective motivation.4
The Arkansas Supreme Court declined to follow Whren on the ground that much of it is dicta. The court reiterated the trial judge’s conclusion that the arrest was pretextual and made for the purpose of searching Sullivan’s vehicle for evidence of a crime. The court also asserted that even if Whren precludes inquiry into an arresting officer’s subjective motivation, there is nothing that prevents this court from interpreting the U. S. Constitution more broadly than the United States Supreme Court. The Arkansas Supreme Court denied the State’s rehearing petition over the dissent of three justices.5
This Court granted the State’s petition for a writ of certiorari and reversed.6
Whether an officer's subjective motivations may invalidate an arrest that is otherwise supported by probable cause?7
Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis.8
No. Although Officer Taylor was aware of narcotics intelligence on Sullivan and noticed a roofing hatchet in the vehicle, the arrest for speeding and other violations was supported by probable cause.9 The inventory search conducted pursuant to police policy uncovered the drugs and paraphernalia.10 Because subjective intentions play no role in ordinary probable-cause Fourth Amendment analysis, the arrest and search did not violate the Fourth Amendment.11
An officer's subjective motivations may not invalidate an arrest that is otherwise supported by probable cause.12
Related opinions on this issue
Justice Ginsburg joined the per curiam opinion while acknowledging the Arkansas Supreme Court's concern rooted in the Fourth Amendment.13 She observed that validating the arrest would accord police officers disturbing discretion to intrude on individuals' liberty and privacy by trailing a targeted vehicle with a driver merely suspected of criminal activity, waiting for the driver to exceed the speed limit by one mile per hour, arresting the driver for speeding, and conducting a full-blown inventory search of the vehicle with impunity.14 Ginsburg noted that this Court has held that such exercises of official discretion are unlimited by the Fourth Amendment under its current case law in Atwater and Whren.15
She expressed hope that the Court's perception of a dearth of horribles proves correct, but if experience demonstrates anything like an epidemic of unnecessary minor-offense arrests, the Court will reconsider its recent precedent.16
Whether a state supreme court may interpret the United States Constitution to provide greater protection to individuals than the precedents of the United States Supreme Court provide?17
A State may not impose greater restrictions as a matter of federal constitutional law when this Court specifically refrains from imposing them.18
No. The Arkansas Supreme Court refused to follow Whren, labeling much of it as dicta, and held that the pretextual arrest warranted suppression of the evidence.19 It further claimed the power to interpret the United States Constitution more broadly than Supreme Court precedent to afford greater protections.20 This position is foreclosed by the rule that a state may not impose greater restrictions as a matter of federal constitutional law when this Court has specifically refrained from doing so.21
A state supreme court may not interpret the United States Constitution to provide greater protection to individuals than the precedents of the United States Supreme Court provide.22