Summary of Michigan v. Long
S. Ct. (1983)
Relevant Facts: Long was pulled over in his vehicle. Subsequent to his arrest the Police performed a “protective search," of the vehicle’s trunk. Therein they found marijauna.
Legal Issue(s): Whether the protective search of vehicle compartments is valid under Terry v Ohio, and is the State S. Ct. ruling adequate and independent of Federal law?
Court’s Holding: The protective search was valid under Terry and the State S. Ct. was not adequate and independent of Federal law.
Law or Rule(s): Absent probable cause police may search “to neutralize the threat of physical harm." If judgment of the State Ct. rests upon two grounds, one of which is federal the other non-federal, S. Ct. jurisdiction fails if the non-federal is independent of federal ground and adequate to support judgment. Fox Film v Muller.
Procedure: Circuit Court of Michigan convicted Defendant of marijuana possession. State Sup. Ct. reversed and suppressed under fruit of poisonous tree doctrine. S. Ct. reversed.
Court Rationale: Apart from two citations to the State Constitution, the state court exclusively relied upon Terry v. Ohio and other federal cases. Not a single state case was cited.
Plaintiff’s Argument: The state exceeded the bounds of federal law which provided the actual basis for its decision.
Defendant’s Argument: No federal interests were offended, Michigan provided greater protection than the federal system. The S. Ct. is only to correct wrong judgments not enter opinions.