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Michigan v. Sitz

Facts

The Michigan State Police established a sobriety checkpoint program pursuant to advisory committee guidelines. Checkpoints could be set up at selected sites along state roads. During operation of the checkpoints, all vehicles would be briefly stopped and the drivers examined for signs of intoxication. If any signs were detected, the individual would be taken out of the flow of traffic and have his driver’s license and registration checked. If necessary, additional sobriety tests would be performed. If officers found the driver to be intoxicated, the driver would be arrested. If not, the driver would be immediately allowed to resume his or her journey. A checkpoint was set up under these guidelines. One hundred twenty six vehicles passed through, with an average delay of approximately 25 seconds per vehicle. Two drivers were detained for additional field sobriety testing, and one of the two was arrested. A third driver drove through the checkpoint and was ultimately stopped and arrested for driving under the influence.

Issue

Whether the government’s use of highway sobriety checkpoints violated the Fourth Amendment?

Held

No. In balancing the interests of the state in eradicating drunk driving with the minimal intrusion upon individual motorists, the checkpoint inspections were reasonable under the Fourth Amendment.

Discussion

Whenever a vehicle is stopped at a checkpoint, a “seizure” under the Fourth Amendment occurs. In Brown v. Texas, the Court outlined a balancing test that applied in this case. Here, the test consisted of “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.” Applying this test, the sobriety checkpoints were constitutional. The States have a substantial interest in eradicating the problem of drunk driving. Alternatively, the intrusion on individual motorists was slight. “In sum, the balance of the State’s interest in preventing drunk driving, the extent to which the 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.”

Citation

496 U.S. 444, 110 S. Ct. 2481 (1990)

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