Unlike cars, the Court explained, boats have no obvious stickers or license plates which can confirm that they are in compliance with the law. Additionally, the Court recognized that unlike cars on highways, boat checkpoints are impractical because there are no established avenues of transport on the water. Schenekl argues that fixed checkpoints at docks or boating ramps would be practical, but we disagree. As the Villamonte Court noted, checkpoints at ports would be easy to avoid. The same holds true for lakes.
Some boaters dock their boats at their homes rather than using public docks or boating ramps.
If checkpoints were established only at public docks, lakeside residents would be forever immune from compliance with boating regulations. Even if checkpoints at docks were established, it would be an ineffective mechanism for enforcement, because a boater could comply with regulations while at the dock but be in noncompliance out on the lake. The State has a strong interest in protecting its citizens. Specifically, we find that the State has a high interest in promoting recreational water safety. In contrast, the level of intrusion involved is minimal.