Wagner v. Sprague, 489 F. App'x 500

Wagner and others sued William Sprague et al. alleging Fourth Amendment violations from a motorcycle checkpoint program.
The district court granted summary judgment in favor of the defendants on the constitutional challenge.
The program was presented as a highway-safety measure with a purported primary purpose of rider safety.
The court recognized the special needs doctrine allows suspicionless searches where primary purpose is not crime control.
On appeal, the Second Circuit affirmed, applying a Brown v. Texas balancing test and upholding the program.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the checkpoint program violates the Fourth Amendment	Wagner argues the program is an unconstitutional search/seizure.	Sprague et al. invoke the special needs doctrine; primary purpose is safety, not crime control.	No constitutional violation; program upheld under special needs balancing.

City of Indianapolis v. Edmond, 531 U.S. 32 (Supreme Court 2000) (special needs searches justified when primary purpose is safety rather than crime control)
Brown v. Texas, 443 U.S. 47 (Supreme Court 1979) (balancing test for public-safety seizures under special needs doctrine)
Delaware v. Prouse, 440 U.S. 648 (Supreme Court 1979) (highway-safety context supports per se considerations of the program)
Lynch v. City of New York, 589 F.3d 94 (2d Cir. 2009) (special needs doctrine can apply when crime-control is not primary purpose)
Kuebel v. Black & Decker, Inc., 643 F.3d 352 (2d Cir. 2011) (standard for reviewing summary judgment on constitutional claims)
Miller v. Wolpoff & Abramson, L.L.P., 321 F.3d 292 (2d Cir. 2003) (summary judgment standard and reasons for evaluating factual disputes)