Michigan v. Long

Michigan v. Long Case Brief

United States Supreme Court
463 U.S. 1032 (1983)

ISSUE: May a police officer search the passenger compartment of a vehicle for weapons if he reasonably believes that the driver is potentially dangerous?
HOLDING: Yes, the balancing required by Terry clearly weighs in favor of allowing the police to conduct an area search of the passenger compartment to uncover weapons as long as they possess an articulable suspicion and objectively reasonable belief that the suspect is potentially dangerous.
FACTS:
  • Two deputies observed a car driving erratically drive into a ditch
  • The deputies approached the driver for his ID and registration and determined that the driver was under the influence of something
  • The officers then observed a large hunting knife on the floor of the car and then subjected D to a Terry stop of his person
  • After shining his flashlight into the car, one officer saw a bag under an armrest, so he pulled it out and found marijuana inside
  • After arresting D, then performed an inventory search of the trunk and found 75 lbs. of marijuana inside
RULES:
  • New York v. Belton: Articles inside the relatively narrow confines of the passenger compartment of an automobile are in fact generally within the area into which an arrestee might reach in order to grab a weapon
REASONING:
  • Terry not limited to searches of the person onlyTerryneed not be read as restricting the preventative search of the person of the detained suspect
  • Can search car in Terry stop: The search of the passenger compartment of an automobile, limited to the areas in which a weapon might be hidden, is permissible when the officers possess a reasonable belief based on specific and articulable facts that the suspect is dangerous and may gain control of the weapons
    • If evidence found during such a search, it needn't be suppressed
COMMENTS:
  • A Long sweep of a car is not part of the Vehicle Doctrine announced in Chambers v. Maroney and California v. Carney, but it is quite similar. The justification in Long is reasonable suspicion, a lower standard than probable cause. If the officer reasonably believes, based on specific and articulable facts, that the vehicle contains weapons that may harm her, she may "patdown" the car without violating the Fourth Amendment.
  • The Long patdown of the car must be as cursory as a Terry patdown of a person must be. Thus an officer can open, for example, a locked glove compartment (but she could with probable cause).

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