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MI Dept. of State Police
v. Sitz
Author:- Kevin Gholami
Body: Procedure: On the day prior to the operation of the Saginaw County checkpoint, respondents filed a complaint in the Circuit Court of Wayne County seeking declaratory and injunctive relief from potential subjection to the checkpoints. The trial court ruled, through the performance of a balancing test derived from Brown v. Texas, that the Michigan program violated the Fourth Amendment and Article 1 of the Michigan Constitution. On appeal, the Michigan Court of Appeals affirmed the holding, by using the same three-prong balancing test, that the program violated the Fourth Amendment and, for that reason, did not consider whether the program violated the Michigan Constitution. After the Michigan Supreme Court denied the petitioners' application for leave of appeal, certiorari was granted by the United States Supreme Court.
Statement of Facts: A sobriety checkpoint was set up in Saginaw County, Michigan, under guidelines set forth by the Sobriety Checkpoint Committee (comprised of state and local police, state prosecutors, and U. of Michigan Transportation Research Institute), to combat drunken driving. During the 75-minute duration of the operation, 126 vehicles passed through the checkpoint. The average delay for each vehicle was 25 seconds. Two drivers were detained for field sobriety testing, of which one was arrested for driving under the influence of alcohol. A third driver, who drove through the checkpoint without stopping, was pulled over and also charged with driving while intoxicated.
Legal Issue: Does a state's use of highway sobriety checkpoints violate the Fourth and Fourteenth Amendments to the United States Constitution?
Holding: No.
Reasoning: (Rhenquist, C.J.) During the original trial and appeal of this case, the Michigan courts used a three-prong balancing test to determine the constitutionality of the checkpoint program. This test involves the balancing of, (1) the state's interest in preventing accidents caused by drunk drivers, (2) the effectiveness of sobriety checkpoints in achieving that goal, and (3) the level of intrusion on an individual's privacy. The Circuit Court of Wayne County and the Michigan Court of Appeals incorrectly concluded that the checkpoint program failed the "effectiveness" part of the test. During the operation of the Saginaw County checkpoint, two of the 126 motorists were charged with driving under the influence. Stated as a percentage, approximately 1.6% of the drivers passing through the checkpoint were arrested for alcohol impairment. By comparison, the record for one of the consolidated cases in Martinez-Fuerte (constitutionality of checkpoints for the detection ! of illegal aliens) showed that in the associated checkpoint, illegal aliens were found in only 0.12% of the vehicles. The ratio of illegal aliens detected to vehicles stopped (considering that there may be multiple illegal aliens per apprehended vehicle) was approximately 0.5%. Based on that record, the particular checkpoint was deemed effective and thus constitutional. In sum, the balance of the state's interest in preventing drunken driving, the extent to which this system can reasonably be said to advance that interest, and the degree of intrusion upon individual motorists who are briefly stopped, weighs in favor of the state program. The program is therefore held consistent with the Fourth Amendment. The judgemnet of the Michigan Court of Appeals is reversed, and the case is remanded for further proceedings not inconsistant with this opinion.