Michigan Department of State Police v. Sitz

Facts

The Michigan Department of State Police and its director set up a sobriety checkpoint pilot program in early 1986. An advisory committee of state police, local police, state prosecutors and University of Michigan researchers wrote guidelines on how checkpoints would operate, how sites would be chosen and how the program would be publicized. Under the guidelines, checkpoints would be set up at selected sites along state roads. Officers would stop all vehicles and briefly examine the drivers for signs of intoxication. A driver who showed signs would be sent out of the traffic flow, where an officer would check the license and registration and, if warranted, give further sobriety tests. If the tests and observations suggested intoxication, the officer would make an arrest. All other drivers could go on at once. The first and only checkpoint ran in Saginaw County for 75 minutes. During that time 126 vehicles passed through, and the average delay was about 25 seconds. Two drivers were held for field sobriety tests, and one of them was arrested for driving under the influence. A third driver, who drove through without stopping, was pulled over by an officer in an observation vehicle and arrested. The respondents were licensed Michigan drivers who regularly travel the State by car. The day before the checkpoint, they filed suit to stop the program. The State Police agreed to delay further checkpoints until the case was decided.

Issues

1. Does a State violate the Fourth and Fourteenth Amendments by using highway sobriety checkpoints at which every approaching vehicle is briefly stopped and its driver examined for signs of intoxication?
2. In balancing the State's interest against the intrusion on motorists, may a court weigh the effectiveness of sobriety checkpoints as searchingly as the Michigan courts did, or does the choice among reasonable law enforcement techniques stay with officials?

Holding

Michigan's sobriety checkpoint program, as challenged, is consistent with the Fourth Amendment. The State's interest in preventing drunken driving, the extent to which the system can reasonably be said to advance that interest and the slight intrusion on briefly stopped motorists together favor the program. The Court addressed only the initial stop and preliminary questioning and observation.