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Michigan Department of State Police v. Sitz: Difference between revisions

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Revision as of 03:17, 23 July 2024 editGcjnst (talk | contribs)Extended confirmed users4,223 edits Holding: Grammar, diction, orthographyTag: Visual edit← Previous edit Latest revision as of 02:48, 7 January 2025 edit undoSkrelk (talk | contribs)Extended confirmed users1,040 edits added paragraph and a sentencing in the lead explaining that upon remand to the Michigan Supreme Court, checkpoints remain prohibited in Michigan 
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'''''Michigan Dept. of State Police v. Sitz''''', 496 U.S. 444 (1990), was a ] case involving the ] of ] ]. The Court held 6-3 that these checkpoints met the ] standard of "reasonable search and seizure." '''''Michigan Dept. of State Police v. Sitz''''', 496 U.S. 444 (1990), was a ] case involving the ] of ] ]. The Court held 6-3 that these checkpoints met the ] standard of "reasonable search and seizure." However, upon remand to the Michigan Supreme Court, that court held that the checkpoints nonetheless violated the Michigan constitution and remain prohibited.


==Background== ==Background==
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==Holding== ==Holding==
The Supreme Court held that Michigan had a "substantial government interest" in stopping drunk driving, and that this technique was rationally related to achieving that goal (although there was some evidence to the contrary). The Court also held that the impact on drivers, such as in delaying them from reaching their destination, was negligible, and that the brief questioning to gain "reasonable suspicion" similarly had a negligible impact on the drivers' Fourth Amendment protection against unreasonable search (implying that any more detailed or invasive searches would be treated differently). Applying a balancing test, the Court found that the constitutionality of the search tilted in favor of the government. The Supreme Court held that Michigan had a "substantial government interest" in stopping drunk driving, and that this technique was rationally related to achieving that goal (although there was some evidence to the contrary). The Court also held that the impact on drivers, such as in delaying them from reaching their destination, was negligible, and that the brief questioning to gain "reasonable suspicion" similarly had a negligible impact on the drivers' Fourth Amendment protection against unreasonable search (implying that any more detailed or invasive searches would be treated differently). Applying a balancing test, the Court found that the constitutionality of the search tilted in favor of the government.

==Subsequent Ruling by Michigan Supreme Court on Remand==

After Sitz was remanded to the Michigan Supreme Court, the Court analyzed the question of whether checkpoints are permitted under the Michigan constitution. The Court concluded that "Because there is no support in the constitutional history of Michigan for the proposition that the police may engage in warrantless and suspicionless seizures of automobiles for the purpose of enforcing the criminal law", checkpoints remain prohibited under Michigan law.<ref>Sitz v. Department of State Police, 443 Mich. 744, 506 N.W.2d 209 (Mich. 1993)</ref>


==See also== ==See also==

Latest revision as of 02:48, 7 January 2025

1990 United States Supreme Court case
Michigan Dept. of State Police v. Sitz
Supreme Court of the United States
Argued February 27, 1990
Decided June 14, 1990
Full case nameMichigan Department Of State Police et al. v. Sitz et al. Certiorari to the Court of Appeals of Michigan
Citations496 U.S. 444 (more)110 S. Ct. 2481; 110 L. Ed. 2d 412; 1990 U.S. LEXIS 3144
Case history
PriorSitz v. Dep't of State Police, 170 Mich. App. 433, 429 N.W.2d 180 (1988); cert. granted, 493 U.S. 806 (1989).
SubsequentOn remand, Sitz v. Dep't of State Police, 193 Mich. App. 690, 485 N.W.2d 135 (1992), affirmed, 443 Mich. 744, 506 N.W.2d 209 (1993).
Holding
Michigan State Police highway sobriety checkpoint program is consistent with the Fourth Amendment.
Court membership
Chief Justice
William Rehnquist
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
Case opinions
MajorityRehnquist, joined by White, O'Connor, Scalia, Kennedy
ConcurrenceBlackmun
DissentBrennan, joined by Marshall
DissentStevens, joined by Brennan, Marshall (Parts I, II)
Laws applied
U.S. Const. amend. IV

Michigan Dept. of State Police v. Sitz, 496 U.S. 444 (1990), was a United States Supreme Court case involving the constitutionality of police sobriety checkpoints. The Court held 6-3 that these checkpoints met the Fourth Amendment standard of "reasonable search and seizure." However, upon remand to the Michigan Supreme Court, that court held that the checkpoints nonetheless violated the Michigan constitution and remain prohibited.

Background

In the state of Michigan, the state police adopted the practice of using random sobriety checkpoints to catch drunk drivers. A group of Michigan residents sued on the grounds that their Fourth Amendment rights prohibiting unreasonable search and seizure were being violated.

As the dissenting opinion by Justice Stevens explains, "a sobriety checkpoint is usually operated at night at an unannounced location. Surprise is crucial to its method. The test operation conducted by the Michigan State Police and the Saginaw County Sheriff's Department began shortly after midnight and lasted until about 1 a.m. During that period, the 19 officers participating in the operation made two arrests and stopped and questioned 124 other unsuspecting and innocent drivers."

During the operation, drivers would be stopped and briefly questioned while in their vehicles. If an officer suspected that a driver was intoxicated, the driver would be subject to a field sobriety test.

Holding

The Supreme Court held that Michigan had a "substantial government interest" in stopping drunk driving, and that this technique was rationally related to achieving that goal (although there was some evidence to the contrary). The Court also held that the impact on drivers, such as in delaying them from reaching their destination, was negligible, and that the brief questioning to gain "reasonable suspicion" similarly had a negligible impact on the drivers' Fourth Amendment protection against unreasonable search (implying that any more detailed or invasive searches would be treated differently). Applying a balancing test, the Court found that the constitutionality of the search tilted in favor of the government.

Subsequent Ruling by Michigan Supreme Court on Remand

After Sitz was remanded to the Michigan Supreme Court, the Court analyzed the question of whether checkpoints are permitted under the Michigan constitution. The Court concluded that "Because there is no support in the constitutional history of Michigan for the proposition that the police may engage in warrantless and suspicionless seizures of automobiles for the purpose of enforcing the criminal law", checkpoints remain prohibited under Michigan law.

See also

External links

United States Fourth Amendment case law
Scope of the Fourth Amendment
Definition of search
Open-fields doctrine
Aerial surveillance
Third-party doctrine
Definition of seizure
Fourth Amendment standing
Probable cause
Reasonable suspicion: Investigative detentions and frisks
Warrant requirement
Mere evidence rule
Neutral and detached magistrate
Warrants directed at third parties
Knock-and-announce
Exceptions to warrant requirement
Exigent circumstances
Consent searches
Plain view
Vehicle searches
Searches incident to arrest
Breathalyzers, blood samples, DNA
Protective sweeps
Inventory searches
Border searches
Checkpoints
Students, employees, and patients
Property of probationers and parolees
Administrative inspections
Searches in jails and prisons
Warrantless arrests
Seizures
Distinguishing stops and arrests
Seizure of premises awaiting warrant
Detention incident to search
Detention during vehicle stop
Excessive force
Remedies
Exclusionary rule
Origins
Impeachment exception
Good-faith exception
Independent source
Inevitable discovery
Attenuation
No-knock searches
Habeas corpus review
Civil suit
Federal
State
Incorporation against States
Unreasonable search and seizure
Warrant requirements
  1. Sitz v. Department of State Police, 443 Mich. 744, 506 N.W.2d 209 (Mich. 1993)
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