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Michigan Dept. of State Police v. Sitz

Supreme Court of the United States · 1990 · Criminal Procedure

Criminal ProcedureFourth AmendmentSobriety CheckpointsFourth Amendmentseizuresobriety checkpointroadblockreasonable suspicion

Facts

The Michigan Department of State Police created a pilot sobriety checkpoint program under guidelines governing operations, site selection, and publicity. At checkpoints, every passing vehicle would be stopped briefly and drivers observed for signs of intoxication; only those showing signs of intoxication would be moved out of traffic for further investigation. The only checkpoint actually conducted lasted 75 minutes, stopped 126 vehicles, imposed an average delay of about 25 seconds per vehicle, and resulted in two drivers being detained for field sobriety testing, one arrest at the checkpoint, and one additional arrest of a driver who drove through without stopping. Respondents were licensed Michigan drivers who regularly traveled throughout the state and challenged the use of the checkpoint program generally.

Issue

Whether Michigan's use of highway sobriety checkpoints, at which all vehicles are briefly stopped and drivers are observed for signs of intoxication without individualized suspicion, violates the Fourth and Fourteenth Amendments.

Rule

A checkpoint stop of a vehicle is a Fourth Amendment seizure, but such a seizure may be reasonable without individualized suspicion when, under the Brown v. Texas balancing approach, the court weighs the State's interest, the degree to which the seizure advances the public interest, and the degree of intrusion on individual motorists, and that balance favors the program.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The highway patrol in Ohio adopts written guidelines for weekend sobriety checkpoints. At a marked checkpoint outside Toledo, uniformed officers stop every car for about 20 seconds, briefly speak with the driver, and look for signs of intoxication; drivers showing no signs are immediately waved on.

A motorist challenges the checkpoint solely because officers lacked individualized suspicion to stop her car. How should a court rule?

Explanation. A checkpoint stop is a Fourth Amendment seizure, but the majority held that individualized suspicion is not always required for the initial brief stop at a sobriety checkpoint. The governing inquiry is the Brown balancing test: the gravity of the public concern, the degree to which the seizure advances the public interest, and the severity of the interference with individual liberty. Where drunk-driving prevention is a grave interest and the stop is brief and minimally intrusive, the initial stop may be reasonable without individualized suspicion. (Derived from Michigan Dept. of State Police v. Sitz (n.d.).)