Monday, November 4, 2013

Michigan Department of State Police v. Sitz case brief

Michigan Department of State Police v. Sitz case brief summary
496 U.S. 444 (1990)

Petitioners, the Michigan Department of State Police and its director, sought review of a judgment from the Court of Appeals of Michigan, which affirmed the circuit court's determination that the State's sobriety checkpoint program violated U.S. Constitutional Amendment IV.

Petitioners set up programs for sobriety checkpoints, and respondents, all licensed drivers, challenged the constitutionality. Respondents argued that the analysis had to proceed from a basis of probable cause or reasonable suspicion, and there must be some governmental need beyond the normal need before a balancing analysis was appropriate.

  • On review the court found that a three prong test was appropriate, balancing the state's grave and legitimate interest in curbing drunk driving; the checkpoints were generally effective, and the subjective intrusion on individual liberties was not substantial. 
  • The court found that a seizure occurred when a vehicle was stopped at a sobriety checkpoint. However, the court held that such stops were reasonable considering the increasing number of alcohol-related deaths and mutilation on the nation's roads. 
  • The State program was consistent with the Fourth Amendment and the balance of the State's interest in preventing drunken driving and the degree of intrusion upon individual motorists who were briefly stopped weighed in favor of the State program.


The judgment finding that the State's sobriety checkpoints were unconstitutional was reversed and remanded for further proceedings consistent with the court's opinion because the proper analysis was a three prong test balancing the state's grave interest in curbing drunk driving, the effectiveness of the stops, and the insubstantial subjective intrusion on individual liberties.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

1 comment:

  1. Lovely just whaat I was looking for. Thanhks to
    the author for taking his time on this one.


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