LaFontaine factors (Georgia) · Go Syfert
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LaFontaine factors in Georgia

8 Georgia opinions name it 2 courts 1998–2018 0 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Baker v. Stategreen
gactapp · 2001 · cited in 3 Georgia opinions naming this issue, 2012–2013
2 sentences

2013Indeed, it is for that reason we specifically noted in Baker that the LaFontaine factors “are not general guidelines but are minimum constitutional prerequisites.” Id. at 701 (1).

2013Indeed, it is for that reason we specifically noted in Baker that the LaFontaine factors “are not general guidelines but are minimum constitutional prerequisites.” Id. at 701 (1).

33
City of Indianapolis v. Edmondgreen
scotus · 2000 · cited in 2 Georgia opinions naming this issue, 2003–2012
2 sentences

2012Accord Edmond, supra at 48 (III) (purpose inquiry is to be conducted at programmatic level, and is not for probing minds of individual officers acting at scene). 8 LaFontaine v. State, 269 Ga. 251 ( 497 SE2d 367 ) (1998) 9 (Citation omitted.) Id. at 253 (3). 3 Only the first of the LaFontaine factors is at issue here: whether the State demonstrated that “the decision to implement the roadblock was made by supervisory personnel rather than the officers in the field.”10 The LaFontaine criteria are the minimum prerequisites that must be met for a roadblock to be constitutional.11 Only after these

2012Accord Edmond, supra at 48 (III) (purpose inquiry is to be conducted at programmatic level, and is not for probing minds of individual officers acting at scene). 8 LaFontaine v. State, 269 Ga. 251 ( 497 SE2d 367 ) (1998) 9 (Citation omitted.) Id. at 253 (3). 3 Only the first of the LaFontaine factors is at issue here: whether the State demonstrated that “the decision to implement the roadblock was made by supervisory personnel rather than the officers in the field.”10 The LaFontaine criteria are the minimum prerequisites that must be met for a roadblock to be constitutional.11 Only after these

22
Brown v. Stategreen
ga · 2013 · cited in 1 Georgia opinions naming this issue, 2013–2013
2 sentences

2013See id. [T]he official who decided to implement the specific checkpoint at issue — the focus of the LaFontaine inquiry — may not be, and need not be, the official or officials whose primary purpose for establishing the agency’s checkpoint program must be determined under Edmond.... [I]n accord with the U. S. Supreme Court’s pre-Edmond checkpoint cases, LaFontaine’s first requirement works to control the potential for arbitrary stops that would exist if every officer in the field could implement a checkpoint by moving the implementation decision up and away from the field to a supervisor.

2013See id. [T]he official who decided to implement the specific checkpoint at issue — the focus of the LaFontaine inquiry — may not be, and need not be, the official or officials whose primary purpose for establishing the agency’s checkpoint program must be determined under Edmond.... [I]n accord with the U. S. Supreme Court’s pre-Edmond checkpoint cases, LaFontaine’s first requirement works to control the potential for arbitrary stops that would exist if every officer in the field could implement a checkpoint by moving the implementation decision up and away from the field to a supervisor.

11
LaFontaine v. Stategreen
ga · 1998 · cited in 1 Georgia opinions naming this issue, 2012–2012
2 sentences

2012Accord Edmond, supra at 48 (III) (purpose inquiry is to be conducted at programmatic level, and is not for probing minds of individual officers acting at scene). 8 LaFontaine v. State, 269 Ga. 251 ( 497 SE2d 367 ) (1998) 9 (Citation omitted.) Id. at 253 (3). 3 Only the first of the LaFontaine factors is at issue here: whether the State demonstrated that “the decision to implement the roadblock was made by supervisory personnel rather than the officers in the field.”10 The LaFontaine criteria are the minimum prerequisites that must be met for a roadblock to be constitutional.11 Only after these

2012Accord Edmond, supra at 48 (III) (purpose inquiry is to be conducted at programmatic level, and is not for probing minds of individual officers acting at scene). 8 LaFontaine v. State, 269 Ga. 251 ( 497 SE2d 367 ) (1998) 9 (Citation omitted.) Id. at 253 (3). 3 Only the first of the LaFontaine factors is at issue here: whether the State demonstrated that “the decision to implement the roadblock was made by supervisory personnel rather than the officers in the field.”10 The LaFontaine criteria are the minimum prerequisites that must be met for a roadblock to be constitutional.11 Only after these

11
Loney v. Stategreen
gactapp · 2000 · cited in 1 Georgia opinions naming this issue, 2003–2003
1 sentence

2003See Loney v. State, 245 Ga. App. at 376 (LaFontaine factors help to ensure roadblocks are not used in an arbitrary or oppressive scheme to detain certain citizens for improper searches).

11
Albert v. Stategreen
gactapp · 1999 · cited in 1 Georgia opinions naming this issue, 2001–2001
2 sentences

2001Instead, the court looks to the “totality of circumstances.” See Albert v. State, 236 Ga. App. 146, 148 ( 511 SE2d 244 ) (1999).

2001Instead, the court looks to the “totality of circumstances.” See Albert v. State, 236 Ga. App. 146, 148 ( 511 SE2d 244 ) (1999).

11
Brent v. Stategreen
ga · 1998 · cited in 1 Georgia opinions naming this issue, 2001–2001
2 sentences

2001The LaFontaine test was reconfirmed in Brent v. State, 270 Ga. 160 ( 510 SE2d 14 ) (1998), in which our Supreme Court ruled that the Georgia Constitution requires no greater protection to the individual than the United States Constitution in balancing the citizen’s right to travel and government’s interest in law enforcement.

2001The LaFontaine test was reconfirmed in Brent v. State, 270 Ga. 160 ( 510 SE2d 14 ) (1998), in which our Supreme Court ruled that the Georgia Constitution requires no greater protection to the individual than the United States Constitution in balancing the citizen’s right to travel and government’s interest in law enforcement.

11
Bohannon v. Stategreen
ga · 1998 · cited in 1 Georgia opinions naming this issue, 1998–1998
2 sentences

1998See Bohannon v. State, 269 Ga. 130 , 497 S.E.2d 552 (1998). 2.

1998See Bohannon v. State, 269 Ga. 130 , 497 S.E.2d 552 (1998). 2.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Georgia. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
State v. Golden green
gactapp · 1984
2 sentences

2018The LaFontaine factors to determine whether a roadblock is satisfactory were adopted by this Court based on the Court of Appeals opinion in State v. Golden, 171 Ga. App. 27 ( 318 SE2d 693 ) (1984).

2018The LaFontaine factors to determine whether a roadblock is satisfactory were adopted by this Court based on the Court of Appeals opinion in State v. Golden, 171 Ga. App. 27 ( 318 SE2d 693 ) (1984).

12018–2018
Price v. State green
ga · 1998
2 sentences

1998LaFontaine's challenge to the admissibility of the blood test results on the ground that the testing procedures have not been properly approved under the Administrative Procedures Act is without merit as that issue was decided adversely to him in Price v. State, 269 Ga. 222 , 498 S.E.2d 262 (1998). 3.

1998LaFontaine's challenge to the admissibility of the blood test results on the ground that the testing procedures have not been properly approved under the Administrative Procedures Act is without merit as that issue was decided adversely to him in Price v. State, 269 Ga. 222 , 498 S.E.2d 262 (1998). 3.

11998–1998

Statutes the citing opinions construe

GA § 40-6-391 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MI 11 (2016–2025) NY 11 (2011–2025) GA 8 (1998–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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