Michigan Department of State Police v. Sitz

Michigan Department of State Police v. Sitz Case Brief

United States Supreme Court
496 U.S. 444 (1990)

ISSUE: Is a highway sobriety checkpoint consistent with the 4th Amdt.'s prohibition on unreasonable seizures?
HOLDING: Yes.
FACTS:
  • Mich. State Police established a sobriety checkpoint pilot program where they used a committee to select locations and methods for the checkpoints
  • One checkpoint was performed on a state road for 1.25 hours, and 126 cars were stopped for an average of 25 seconds and 2 drivers were arrested for DUI
PROCEDURAL HISTORY:
  • Trial Ct. found the checkpoint violated the 4th Amdt.
  • Mich. Ct. App. affirmed and Sup. Ct. denied petition for review
REASONING:
  • Seizure: Stopping motorists at checkpoints is a seizure that invokes the protections of the 4th Amdt.
  • Govt. interest: Drunk driving is a serious problem, so the state has a strong interest
  • Private interest: The intrusion bearing on motorists stopped at the checkpoints is slight as they are only detained briefly and any concern or fear would be slight
  • Reasonable seizures: The balancing of the State's interest with the interests of the motorists weighs in favor of the State
COMMENTS:
  • Since checkpoint stops are not justified by any objective criterion like probable cause or reasonable suspicion, one may inquire into pretext just like inventory searches (see South Dakota v. Opperman). Checkpoint stops must leave no discretion to the officers. They also must be marked, brief, and not unduly taxing on citizens.
  • The most important limitation on a valid checkpoint is that the purpose of the checkpoint must be a legitimate public safety concern reasonably related to the vehicle context and not just general crime control. Valid checkpoints thus far have included ones for drunk drivers, illegal aliens near the border, and information-gathering (see Illinois v. Lidster). However, a checkpoint for drugs is violative of the Fourth Amendment because its primary purpose is essentially general crime control (see City of Indianapolis v. Edmond).

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