Michigan V. Sitz
Oriana McGrath
POSC
Michigan Department of State Police v. Sitz Case Brief
FACTS: The Michigan State Police established a sobriety checkpoint pilot program that went on for only one day. “Under the guidelines, checkpoints would be set up at selected sites along state roads. All vehicles passing through a checkpoint would be stopped and their drivers briefly examined for signs of intoxication. In cases where a checkpoint officer detected signs of intoxication, the motorist would be directed to a location out of the traffic flow where an officer would check the motorist’s driver’s license and car registration and, if warranted, conduct further sobriety tests. Should the field tests and the officer’s observations suggest that the driver was intoxicated, an arrest would be made. All other drivers would be permitted to resume their journey immediately.”
One day before the operation, a group of Michigan residents that were led by Sitz, filed suit to obtain declaratory and injunctive relief from subjection to the checkpoints. The Michigan Police Department agreed to postpone further implementation of the checkpoints pending the outcome of the litigation. The trial court ruled that the program violated the 4th and 14th Amendments. On appeal, The Michigan Court of Appeals affirmed the holding that the program violated the Constitution. The Michigan Supreme Court denied the petitioners’ application for leave to appeal, and the U.S. Supreme Court granted certiorari.
QUESTION: Does a State’s use of highway sobriety checkpoints violate the 4th and 14th Amendments of the United States Constitution?
HOLDING: Reversed & Remanded; Michigan State Police highway sobriety checkpoint program is not a violation of the 4th and 14th Amendments.
RATIONALE: To decide the outcome of this case the court used a three-prong balancing test from Brown v. Texas to determine the constitutionality of the checkpoint program. The test balanced the state’s interest in preventing accidents
POSC
Michigan Department of State Police v. Sitz Case Brief
FACTS: The Michigan State Police established a sobriety checkpoint pilot program that went on for only one day. “Under the guidelines, checkpoints would be set up at selected sites along state roads. All vehicles passing through a checkpoint would be stopped and their drivers briefly examined for signs of intoxication. In cases where a checkpoint officer detected signs of intoxication, the motorist would be directed to a location out of the traffic flow where an officer would check the motorist’s driver’s license and car registration and, if warranted, conduct further sobriety tests. Should the field tests and the officer’s observations suggest that the driver was intoxicated, an arrest would be made. All other drivers would be permitted to resume their journey immediately.”
One day before the operation, a group of Michigan residents that were led by Sitz, filed suit to obtain declaratory and injunctive relief from subjection to the checkpoints. The Michigan Police Department agreed to postpone further implementation of the checkpoints pending the outcome of the litigation. The trial court ruled that the program violated the 4th and 14th Amendments. On appeal, The Michigan Court of Appeals affirmed the holding that the program violated the Constitution. The Michigan Supreme Court denied the petitioners’ application for leave to appeal, and the U.S. Supreme Court granted certiorari.
QUESTION: Does a State’s use of highway sobriety checkpoints violate the 4th and 14th Amendments of the United States Constitution?
HOLDING: Reversed & Remanded; Michigan State Police highway sobriety checkpoint program is not a violation of the 4th and 14th Amendments.
RATIONALE: To decide the outcome of this case the court used a three-prong balancing test from Brown v. Texas to determine the constitutionality of the checkpoint program. The test balanced the state’s interest in preventing accidents