Michigan v. Long
Headline: Court allows police to search a stopped car’s passenger area for weapons without an arrest when officers reasonably fear for their safety, making it easier to check for hidden weapons during roadside stops.
Holding: The Court held that officers may conduct a limited weapons search of a stopped vehicle’s passenger compartment during an investigatory stop if they have specific, articulable facts to reasonably believe the driver is armed and dangerous.
- Allows officers to search passenger compartment for weapons during investigatory stops with reasonable suspicion.
- Permits seizure of contraband plainly observed during a justified safety search.
- Leaves the trunk-search legality to state court review on remand.
Summary
Background
Deputies Howell and Lewis stopped David Long after seeing his car travel erratically and swerve into a ditch late at night. Long, the only occupant, appeared impaired and a large hunting knife was seen on the driver’s floorboard. After a patdown found no weapon, an officer shone a flashlight into the car, lifted an armrest, and saw a pouch that appeared to contain marihuana. Long was arrested; further searches of the interior and an unlocked trunk uncovered large quantities of marihuana. Trial court and Court of Appeals upheld the searches, but the Michigan Supreme Court reversed and suppressed the evidence.
Reasoning
The key question was whether a protective weapons search under Terry can extend to a vehicle’s passenger compartment during an investigatory stop. The Court held that it can, but only when an officer has specific and articulable facts that would lead a reasonable officer to believe the suspect is armed and dangerous. The search must be limited to areas where a weapon may be placed or hidden. The opinion relies on Terry and later decisions (Mimms, Adams, Chimel, Belton) and explains that if contraband is plainly discovered during a valid safety search, it need not be suppressed. Because the Michigan Supreme Court did not resolve whether the trunk search was lawful under inventory or other rules, the Court remanded that issue to the state court.
Real world impact
The ruling lets police conduct limited area searches of a stopped vehicle’s passenger compartment for officer safety when there is a reasonable, articulable belief of danger. Contraband seen during such a search may be used in prosecution. The legality of the trunk search was left for the Michigan courts to decide.
Dissents or concurrances
Justice Blackmun joined much of the opinion but did not join the new jurisdiction presumption. Justice Brennan dissented, warning the decision expands Terry and weakens probable-cause protections; Justice Stevens dissented on jurisdictional grounds.
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