Location specific bank robbery roadblock was valid

Houston P.D. roadblock for bank robbery suspect was valid under Edmund and Lidster where it was set on the escape route from the bank robbery based on the signal from the beeper pack. United States v. Abbott, 265 Fed. Appx. 307 (5th Cir. 2008) (unpublished):

With respect to the roadblock, the district court likewise did not err. Roadblocks designed to address specialized law-enforcement purposes may be permissible without the presence of individualized suspicion, provided the court finds a favorable balance between “the gravity of the public concerns served by the seizure, the degree to which the seizure advances the public interest, and the severity of the interference with individual liberty”. Brown v. Texas, 443 U.S. 47, 50-51, 99 S. Ct. 2637, 61 L. Ed. 2d 357 (1979); see also Lidster, 540 U.S. at 424.

The roadblock was a targeted law-enforcement effort designed to address a specific and dangerous crime–an armed bank robbery–about which the HPD had particularized knowledge. Utilizing the ETDs, the Officers were able to narrow their search to a relatively small area in which there was a high likelihood of apprehending the suspects. Thus, the roadblock was properly tailored to detect evidence of a particular criminal wrongdoing rather than for general crime control. See Lidster, 540 U.S. at 424; see also Edmond, 531 U.S. at 44 (“an appropriately tailored roadblock set up to … catch a dangerous criminal who is likely to flee by way of a particular route” would “almost certainly” be permissible). Accordingly, it was not unconstitutional per se.

Further, the roadblock was not unreasonable under the circumstances, and it satisfies the requirements of the Brown balancing test. The public concern of apprehending armed bank robbers was substantial; the roadblock was tailored in both time and place, based on evidence extracted from the ETDs; and any objective intrusion on civil liberties was minimal and brief.