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Michigan Department of State Police v. Sitz

    Citation. 496 U.S. 444, 110 S. Ct. 2481, 110 L. Ed. 2d 412 (1990)

    Brief Fact Summary. The constitutionality of a sobriety check point was at issue.

    Synopsis of Rule of Law. The checkpoint program is consistent with the Fourth Amendment because “the balance of the State’s interest in preventing drunken driving, the extent to which this system can reasonably be said to advance that interest, and the degree of intrusion upon individual motorists who are briefly stopped, weighs in favor of the state program.”


    Facts. The Michigan State Police established a sobriety checkpoint pilot program. It only went on for one day. “Under the guidelines, checkpoints would be set up at selected sites along state roads. All vehicles passing through a checkpoint would be stopped and their drivers briefly examined for signs of intoxication. In cases where a checkpoint officer detected signs of intoxication, the motorist would be directed to a location out of the traffic flow where an officer would check the motorist’s driver’s license and car registration and, if warranted, conduct further sobriety tests. Should the field tests and the officer’s observations suggest that the driver was intoxicated, an arrest would be made. All other drivers would be permitted to resume their journey immediately.”
    The Respondents, licensed drivers in that the state of Michigan (the “Respondents”), filed suit to obtain declaratory and injunctive relief from subjection to the checkpoints. The Michigan Police Department agreed to postpone further implementation of the check points pending the outcome of the litigation. The trial court ruled that the program violated the Fourth Amendment. The Michigan Court of Appeals affirmed. The Michigan Supreme Court refused to hear this case.

    Issue. “[W]hether a State’s use of highway sobriety checkpoints violates the Fourth and Fourteenth Amendments to the United States Constitution[?]”

    Held. The court first observed that the police department agrees there is a Fourth Amendment “seizure” when a vehicle is stopped at a checkpoint. Also, that the question becomes whether the stop is “reasonable” under the Fourth Amendment. The majority went out of its way to point out, “[a]s pursued in the lower courts, the instant action challenges only the use of sobriety checkpoints generally. We address only the initial stop of each motorist passing through a checkpoint and the associated preliminary questioning and observation by checkpoint officers.” The court found that the appropriate test to be applied is the balancing test from [Brown v. Texas], which involves “balancing the state’s interest in preventing accidents caused by drunk drivers, the effectiveness of sobriety checkpoints in achieving that goal, and the level of intrusion on an individual’s privacy caused by the checkpoints.”
    “No one can seriously dispute the magnitude of the drunken driving problem or the States’ interest in eradicating it. Media reports of alcohol-related death and mutilation on the Nation’s roads are legion. The anecdotal is confirmed by the statistical.” On the other hand, “the weight bearing on the other scale – the measure of the intrusion on motorists stopped briefly at sobriety checkpoints – is slight. [The Court] reached a similar conclusion as to the intrusion on motorists subjected to a brief stop at a highway checkpoint for detecting illegal aliens. We see virtually no difference between the levels of intrusion on law-abiding motorists from the brief stops necessary to the effectuation of these two types of checkpoints, which to the average motorist would seem identical save for the nature of the questions the checkpoint officers might ask. The trial court and the Court of Appeals, thus, accurately gauged the ‘objective’ intrusion, measured by the duration of the seizure an
    d the intensity of the investigation, as minimal.”
    As to the subjective intrusion on individual drivers the majority observed, “[t]he ‘fear and surprise’ to be considered are not the natural fear of one who has been drinking over the prospect of being stopped at a sobriety checkpoint but, rather, the fear and surprise engendered in law-abiding motorists by the nature of the stop.”
    “Here, checkpoints are selected pursuant to the guidelines, and uniformed police officers stop every approaching vehicle. The intrusion resulting from the brief stop at the sobriety checkpoint is for constitutional purposes indistinguishable from the checkpoint stops we upheld in [Martinez-Fuerte].”
    The Michigan Court of Appeals inappropriately construed the effectiveness of the program. The majority observed “for purposes of Fourth Amendment analysis, the choice among such reasonable alternatives remains with the governmental officials who have a unique understanding of, and a responsibility for, limited public resources, including a finite number of police officers.”
    Further, “[u]nlike [Prouse], this case involves neither a complete absence of empirical data nor a challenge to random highway stops. During the operation of the Saginaw County checkpoint, the detention of the 126 vehicles that entered the checkpoint resulted in the arrest of two drunken drivers. Stated as a percentage, approximately 1.6 percent of the drivers passing through the checkpoint were arrested for alcohol impairment. In addition, an expert witness testified at the trial that experience in other States demonstrated that, on the whole, sobriety checkpoints resulted in drunken driving arrests of around 1 percent of all motorists stopped. By way of comparison, the record from one of the consolidated cases in [Martinez-Fuerte] showed that in the associated checkpoint, illegal aliens were found in only 0.12 percent of the vehicles passing through the checkpoint. The ratio of illegal aliens detected to vehicles stopped (considering that on occasion two or more illegal aliens
    were found in a single vehicle) was approximately 0.5 percent. We concluded that this ‘record. . . provides a rather complete picture of the effectiveness of the San Clemente checkpoint,’ and we sustained its constitutionality. We see no justification for a different conclusion here.”
    Dissent: Justice Stevens, Justice Brennan and Justice Marshall filed a dissenting opinion. “[I]t seems evident that the Court today misapplies the balancing test announced in [Brown v. Texas]. The Court overvalues the law enforcement interest in using sobriety checkpoints, undervalues the citizen’s interest in freedom from random, announced investigatory seizures, and mistakenly assumes that there is ‘virtually no difference’ between a routine stop at a permanent, fixed checkpoint and a surprise stop at a sobriety checkpoint. [The dissenting justices] believe this case is controlled by our several precedents condemning suspicionless random stops of motorists for investigatory purposes.”

    Discussion. In is interesting to read the majority and dissenting opinions along side one another so as to see how the different judges reach their decisions.

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