Michigan Department of State Police v. Sitz

Michigan Dept. of State Police v. Sitz
Supreme Court of the United States
Argued February 27, 1990 Decided June 14, 1990
Full case name	Michigan Department Of State Police et al. v. Sitz et al. Certiorari to the Court of Appeals of Michigan
Citations	496 U.S. 444 (more) 110 S. Ct. 2481; 110 L. Ed. 2d 412; 1990 U.S. LEXIS 3144
Case history
Prior	Sitz v. Dep't of State Police, 170 Mich. App. 433, 429 N.W.2d 180 (1988); cert. granted, 493 U.S. 806 (1989).
Subsequent	On remand, Sitz v. Dep't of State Police, 193 Mich. App. 690, 485 N.W.2d 135 (1992), affirmed, 443 Mich. 744, 506 N.W.2d 209 (1993).
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 P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy
Case opinions
Majority	Rehnquist, joined by White, O'Connor, Scalia, Kennedy
Concurrence	Blackmun
Dissent	Brennan, joined by Marshall
Dissent	Stevens, joined by Brennan, Marshall (Parts I, II)
Laws applied
U.S. Const. amend. IV

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. The Court held 6-3 that these checkpoints met the Fourth Amendment standard of "reasonable search and seizure."

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.

As the dissenting opinion by Justice Stevens explains, "a sobriety checkpoint is usually operated at night at an unannounced location. Surprise is crucial to its method. The test operation conducted by the Michigan State Police and the Saginaw County Sheriff's Department began shortly after midnight and lasted until about 1 a.m. During that period, the 19 officers participating in the operation made two arrests and stopped and questioned 124 other unsuspecting and innocent drivers."

During the operation, drivers would be stopped and briefly questioned while in their vehicles. If an officer suspected that a driver was intoxicated, the driver would be subject to a field sobriety test.

The Supreme Court held that Michigan had a "substantial government interest" in stopping drunk driving, and that this technique was rationally related to achieving that goal (although there was some evidence to the contrary). The Court also held that the impact on drivers, such as in delaying them from reaching their destination, was negligible, and that the brief questioning to gain "reasonable suspicion" similarly had a negligible impact on the drivers' Fourth Amendment protection against unreasonable search (implying that any more detailed or invasive searches would be treated differently). Applying a balancing test, the Court found that the constitutionality of the search tilted in favor of the government.

• Illinois v. Lidster (2004)
• United States v. Martinez-Fuerte (1976)
• List of United States Supreme Court cases, volume 496

• Works related to Michigan Department of State Police v. Sitz at Wikisource
• Text of Michigan Dept. of State Police v. Sitz, 496 U.S. 444 (1990) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)