Michigan v. Long

463 U.S. 1032 (1983)

Facts

The Michigan State Supreme Court reversed Defendant Long's conviction of illegal possession of marijuana. The state court found that Long's conviction directly resulted from evidence obtained through an unreasonable search or seizure in violation of the Fourth Amendment. As 'fruit' of poisonous tree, the damaging evidence was inadmissible against the Defendant. However, the state continued to pursue admissibility of the evidence in the United States Supreme Court to convict the Defendant. The Defendant contested, asserting that federal judicial review was unavailable to the U.S. Supreme Court to overturn his conviction because the state's decision had been rendered on 'adequate and independent grounds.' In addition, the Defendant argued that Michigan's unlawful search and seizure provisions are more expansive than federal Fourth Amendment protection. Nevertheless, the state court heavily relied on federal Fourth Amendment law in rendering its decision in favor the Defendant. In this opinion, the U.S. States Supreme Court reverses the decision of the state court. (See more on Terry issue below).