Michigan Department Of State Police v. Sitz

496 U.S. 444 (1990)

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Nature of the Case

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Facts

Michigan established a sobriety checkpoint pilot program that determined locations and the guidelines for a sobriety checkpoint program. The rules were simple; all vehicles passing through the checkpoint were stopped, and the drivers were examined for intoxication. If there were signs of intoxication, the driver was ordered off to the roadside for further checks, such as their driver license and car registration and if warranted further sobriety tests. An arrest was made if the driver was found to be intoxicated. All other drivers were permitted to resume their travels immediately. In the first test, the average delay was 25 seconds, and two drivers were detained for further tests and one of the two were arrested. A third was arrested for DUI when he refused to stop. Sitz (P) filed a complaint on the day before the first checkpoint was implemented asking for declaratory relief and an injunction. The court ruled that the program violated the Fourth Amendment. The Court of Appeals affirmed. The lower court and the court of appeals used the Brown three-prong balance test to determine constitutionality. The Supreme Court granted certiorari.