Michigan Department of State Police v. Sitz

1990 United States Supreme Court case

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."

## Background

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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.

## Holding

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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.

## See also

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

## External links

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* 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)

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United States Fourth Amendment case law

Scope of the Fourth Amendment

| Definition of search|

* Boyd v. United States (1886)
* United States v. Lee (1927)
* Olmstead v. United States (1928)
* Abel v. United States (1960)
* Silverman v. United States (1961)
* Katz v. United States (1967)
* United States v. Knotts (1983)
* United States v. Place (1983)
* United States v. Karo (1984)
* California v. Greenwood (1988)
* Skinner v. Railway Labor Executives Ass'n (1989)
* United States v. Verdugo-Urquidez (1990)
* Bond v. United States (2000)
* Kyllo v. United States (2001)
* Illinois v. Caballes (2005)
* United States v. Jones (2012)
* Florida v. Jardines (2013)
* Klayman v. Obama (D.D.C. 2013)
* ACLU v. Clapper (D.D.C. 2013)

| Open-fields doctrine|

* Hester v. United States (1924)
* Oliver v. United States (1984)
* United States v. Dunn (1987)

|

Aerial surveillance|

* California v. Ciraolo (1986)
* Dow Chemical Co. v. United States (1986)
* Florida v. Riley (1989)

Third-party doctrine|

* United States v. White (1971)
* United States v. Miller (1976)
* Smith v. Maryland (1979)
* Carpenter v. United States (2018)

Definition of seizure|

* Counselman v. Hitchcock (1892)
* Hale v. Henkel (1906)
* Terry v. Ohio (1968)
* United States v. Mendenhall (1980)
* Florida v. Royer (1983)
* INS v. Delgado (1984)
* California v. Hodari D. (1991)
* Florida v. Bostick (1991)
* Soldal v. Cook County (1992)
* United States v. Drayton (2002)
* Brendlin v. California (2007)
* Torres v. Madrid (2021)

Fourth Amendment standing|

* Rakas v. Illinois (1978)
* Byrd v. United States (2018)

Probable cause

* Brinegar v. United States (1949)
* Aguilar v. Texas (1964)
* Spinelli v. United States (1969)
* Illinois v. Gates (1983)
* Ornelas v. United States (1996)
* Whren v. United States (1996)
* Maryland v. Pringle (2003)
* Devenpeck v. Alford (2004)
* Florida v. Harris (2013)
* District of Columbia v. Wesby (2018)

Reasonable suspicion: Investigative detentions and frisks

* Terry v. Ohio (1968)
* United States v. Brignoni-Ponce (1975)
* Delaware v. Prouse (1979)
* Brown v. Texas (1979)
* Ybarra v. Illinois (1979)
* United States v. Cortez (1981)
* United States v. Place (1983)
* Michigan v. Long (1983)
* Minnesota v. Dickerson (1996)
* Illinois v. Wardlow (2000)
* Florida v. J. L. (2000)
* United States v. Arvizu (2002)
* Hiibel v. Sixth Judicial District Court of Nevada (2004)
* Arizona v. Johnson (2009)
* Navarette v. California (2014)
* Heien v. North Carolina (2014)
* Kansas v. Glover (2020)

Warrant requirement

* Johnson v. United States (1948)
* Franks v. Delaware (1978)
* Ybarra v. Illinois (1979)
* Maryland v. Garrison (1987)
* United States v. Grubbs (2006)
* Los Angeles County v. Rettelle (2006)

| Mere evidence rule|

* Boyd v. United States (1886)
* Hale v. Henkel (1906)
* Warden v. Hayden (1967)

|

Neutral and detached magistrate|

* Coolidge v. New Hampshire (1971)

Warrants directed at third parties|

* Zurcher v. Stanford Daily (1978)

Knock-and-announce|

* Wilson v. Arkansas (1995)

Exceptions to warrant requirement

| Exigent circumstances|

* Warden v. Hayden (1967)
* United States v. Chadwick (1977)
* Payton v. New York (1980)
* Welsh v. Wisconsin (1986)
* Brigham City v. Stuart (2006)
* Kentucky v. King (2011)
* Caniglia v. Strom (2021)
* Lange v. California (2021)

|

Consent searches|

* Stoner v. California (1968)
* Schneckloth v. Bustamonte (1973)
* United States v. Matlock (1974)
* Illinois v. Rodriguez (1990)
* Georgia v. Randolph (2006)
* Fernandez v. California (2014)

Plain view|

* Coolidge v. New Hampshire (1971)
* Arizona v. Hicks (1987)
* Horton v. California (1990)
* Minnesota v. Dickerson (1993)

Vehicle searches|

* Carroll v. United States (1925)
* Chambers v. Maroney (1970)
* Arkansas v. Sanders (1979)
* United States v. Ross (1982)
* California v. Carney (1985)
* Florida v. Jimeno (1991)
* California v. Acevedo (1991)
* Wyoming v. Houghton (1999)
* Florida v. White (1999)
* Collins v. Virginia (2018)

Searches incident to arrest|

* Trupiano v. United States (1948)
* United States v. Rabinowitz (1950)
* Chimel v. California (1969)
* United States v. Robinson (1973)
* United States v. Chadwick (1977)
* New York v. Belton (1981)
* Knowles v. Iowa (1998)
* Thornton v. United States (2004)
* Arizona v. Gant (2009)
* Riley v. California (2014)

Breathalyzers, blood samples, DNA|

* Schmerber v. California (1966)
* Cupp v. Murphy (1973)
* Missouri v. McNeely (2013)
* Maryland v. King (2013)
* Birchfield v. North Dakota (2016)
* Mitchell v. Wisconsin (2019)

Protective sweeps|

* Maryland v. Buie (1990)

Inventory searches|

* Cady v. Dombrowski (1973)
* South Dakota v. Opperman (1976)
* Colorado v. Bertine (1987)

Border searches|

* Almeida-Sanchez v. United States (1973)
* United States v. Ortiz (1975)
* United States v. Martinez-Fuerte (1976)
* United States v. Ramsey (1977)
* United States v. Montoya De Hernandez (1985)
* United States v. Flores-Montano (2004)

Checkpoints|

* Michigan Department of State Police v. Sitz (1990)
* City of Indianapolis v. Edmond (2000)
* Illinois v. Lidster (2004)

Students, employees, and patients|

* New Jersey v. T. L. O. (1985)
* O'Connor v. Ortega (1987)
* Skinner v. Railway Labor Executives Ass'n (1989)
* National Treasury Employees Union v. Von Raab (1989)
* Vernonia School District 47J v. Acton (1995)
* Chandler v. Miller (1997)
* Ferguson v. City of Charleston (2001)
* Board of Education v. Earls (2002)
* Safford Unified School District v. Redding (2009)
* City of Ontario v. Quon (2010)

Property of probationers and parolees|

* Samson v. California (2006)

Administrative inspections|

* Frank v. Maryland (1959)
* Camara v. Municipal Court (1967)
* City of Los Angeles v. Patel (2015)

Searches in jails and prisons|

* Bell v. Wolfish (1979)
* Hudson v. Palmer (1984)
* Florence v. Board of Chosen Freeholders (2012)

Warrantless arrests|

* United States v. Watson (1976)
* Payton v. New York (1980)
* Welsh v. Wisconsin (1983)
* County of Riverside v. McLaughlin (1991)
* Atwater v. City of Lago Vista (2001)
* Virginia v. Moore (2008)

Seizures

| Distinguishing stops and arrests|

* Dunaway v. New York (1979)
* Florida v. Royer (1983)
* United States v. Place (1983)

|

Seizure of premises awaiting warrant|

* Illinois v. McArthur (2001)

Detention incident to search|

* Michigan v. Summers (1981)
* Muehler v. Mena (2005)
* Bailey v. United States (2013)

Detention during vehicle stop|

* Pennsylvania v. Mimms (1977)
* Rodriguez v. United States (2015)

Excessive force|

* Tennessee v. Garner (1985)
* Graham v. Connor (1989)
* Scott v. Harris (2007)
* Plumhoff v. Rickard (2014)
* Mullenix v. Luna (2015)
* Barnes v. Felix (2025)

Remedies

| Exclusionary rule|

| Origins|

* Weeks v. United States (1914)
* Silverthorne Lumber Co. v. United States (1920)

|

Impeachment exception|

* James v. Illinois (1990)

Good-faith exception|

* United States v. Leon (1984)
* Herring v. United States (2009)
* Davis v. United States (2011)

Independent source|

* Murray v. United States (1988)

Inevitable discovery|

* Nix v. Williams (1984)

Attenuation|

* Wong Sun v. United States (1963)
* Utah v. Strieff (2016)

No-knock searches|

* Hudson v. Michigan (2006)

Habeas corpus review|

* Stone v. Powell (1976)
* Kimmelman v. Morrison (1986)

Civil suit|

| Federal|

* Bivens v. Six Unknown Named Agents (1971)
* Egbert v. Boule (2022)

|

State|

* 42 U.S.C. § 1983
* Monroe v. Pape (1961)

Incorporation against States

| Unreasonable search and seizure|

* Wolf v. Colorado (1949)
* Rochin v. California (1952)
* Elkins v. United States (1960)
* Mapp v. Ohio (1961)

|

Warrant requirements|

* Ker v. California (1963)
* Aguilar v. Texas (1964)

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