Michigan Department of State Police v. Sitz

1990-06-14

Headline: States may run highway sobriety checkpoints; Court upholds brief, suspicionless stops and allows police to briefly stop all motorists for sobriety checks, affecting drivers and police enforcement practices nationwide.

Holding: The Court held that a State's use of highway sobriety checkpoints does not violate the Fourth Amendment and allowed brief, systematic stops of all motorists for preliminary sobriety checks.

Real World Impact:

Allows police to stop all cars briefly at highway sobriety checkpoints.
Typical delays will be short; Michigan test averaged about 25 seconds.
Enables states to use checkpoints publicly to deter drunk driving.

Topics: drunk driving checkpoints, police stops, traffic safety, civil liberties

Summary

Background

In early 1986 the Michigan State Police set up a pilot sobriety checkpoint program and an advisory committee created guidelines for site selection, operation, and publicity. The only checkpoint run under the program was in Saginaw County. During a 75-minute test, officers stopped 126 vehicles, delaying each about 25 seconds on average; two drivers were taken aside for field tests and one was arrested at the checkpoint, while a third who drove through was later stopped and arrested. Several licensed drivers challenged the program in state court, which struck it down; the state appealed to the Supreme Court.

Reasoning

The Supreme Court treated the brief stops as seizures but applied a balancing approach: weigh the State’s strong interest in preventing drunk driving against the intrusiveness of the stops. The Court found the public safety interest very large, the intrusion on law‑abiding motorists minimal, and some evidence that checkpoints can detect or deter impaired driving. Relying on earlier highway‑checkpoint decisions, the Court concluded the balance favors allowing the program and reversed the Michigan Court of Appeals.

Real world impact

The ruling permits states and local police to operate brief, systematic sobriety checkpoints under guidelines like Michigan’s. Drivers can be required to stop briefly at such checkpoints (Michigan’s test averaged about 25 seconds). The decision does not license unlimited detention or improper officer conduct and leaves room for later challenges to particular checkpoints or longer detentions that would raise different legal issues.

Dissents or concurrances

Justice Blackmun concurred in the judgment. Justices Brennan and Stevens dissented, arguing checkpoints are intrusive, rely on surprise, yield low arrest rates, and that stopping every car without individualized suspicion risks harassment and may not improve safety.