Michigan Dept. of State Police v. Sitz
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| Michigan Dept. of State Police v. Sitz | ||||||||||
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| Argued February 27, 1990 Decided June 14, 1990 |
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| 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 Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy |
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| Case opinions | ||||||||||
| Majority by: Rhenquist Joined by: White, O'Connor, Scalia, Kennedy Concurrence by: Blackmun Dissent by: Brennan Joined by: Marshall Dissent by: Stevens Joined by: Brennan, Marshall |
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| Laws applied | ||||||||||
| Fourth Amendment | ||||||||||
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. By a vote of 6-3, the Court held that these checkpoints did not meet the Fourth Amendment standard of "unreasonable search and seizure."
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[edit] 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.
[edit] Majority opinion
- To decide if the seizure practiced at the sobriety checkpoints is constitutional, we must apply the balancing test as explained in Brown v. Texas. This weighs the state’s interest of preventing drunk driving against the effectiveness of checkpoints and the level of intrusion on driver’s privacy. The state interest is obviously large; drunk driving is a huge problem. The effectiveness of the checkpoints is not for the Court to gauge. The law enforcement officials make decisions about how to best fight crime and (as long as their practices are constitutional) we should trust them because they are experts. As to the amount of intrusion on the average driver, the Court believes it to be slight. Law abiding citizens are only stopped for a moment and can then be on their way. The Court writes off the issue of fear and surprise.
- In Delaware v. Prouse the Court ruled that the police stopping random vehicles for no reason other than to check their licenses was unconstitutional. This situation is different from that because every car is checked. In Delaware there was a "standardlessness" which is not present in this case.
- The Court believes that the state interest of drunk driving prevention outweighs the amount of intrusion onto average motorists. Thus, the Brown balancing test is satisfied and the sobriety checkpoints are constitutional.
[edit] Dissents
[edit] Brennan
Joined by Marshall.
- To apply the Brown balancing test, the seizure must be minimally intrusive. We do not believe that the majority even addressed this issue.
- Because everyone must stop at the checkpoint, we could be subjecting "the general public to arbitrary or harassing conduct by the police."
- We should be suspicious of giving up constitutional rights, no matter how insignificant they may be perceived, to fight "momentary evils." Drunk driving is a momentary evil and the Court is not protecting the public’s "most valued right" – the right to be left alone.
[edit] Stevens
Joined by Brennan and Marshall.
- Surprise is the method of the Michigan police in catching drunk drivers at sobriety checkpoints. The effectiveness of this method is questionable – we cannot measure how many drunk drivers would have been caught by other means. The effect of traffic stops on public safety is trivial and maybe negative. In Maryland, they did a similar program and found that only 0.3% (143 people) of drivers passing through checkpoints were arrested. Comparing that number with the 71,000 Michigan drivers arrested for drunk driving last year without checkpoints it is obvious that checkpoints are a very small element of the fight against drunk driving. Is this small effect worth the possibly large infringement on the Fourth Amendment rights of motorists? We believe that it is not.
- There is a difference between a routine seizure (like at a border checkpoint) and a surprise one. A random sobriety checkpoint like these can easily violate the rights of drivers through the distress caused by a night-time surprise.
- The court is looking only at the benefits of checkpoints and not at the cost to drivers who have to give up a fraction of their constitutional rights for this policy.
