Michigan v. Long Case Brief

Facts of the case

David Long was convicted for possession of marijuana found by Michigan police in the passenger compartment and trunk of his car. The police searched the passenger compartment because they suspected Long’s vehicle contained weapons potentially dangerous to the officers. After a state appellate court affirmed the conviction, the Michigan Supreme Court reversed. The Michigan Supreme Court held that the search violated the Fourth Amendment and the Michigan Constitution.

Why is the case important?

David Long was convicted for possession of marijuana found by police in the passenger compartment and trunk of the automobile that he was driving. Long filed a motion to suppress the marijuana taken from his vehicle.

Question

If there is not probable cause for arrest, can a protective search for weapons extend to an area beyond the person?
Does Long’s claim that the Michigan Supreme Court acted on independent and adequate state grounds eliminate the Supreme Court’s jurisdiction to hear this case?

ANSWER

The United States Supreme Court (Supreme Court) reversed the decision of the Michigan Supreme Court. The Supreme Court held that the protective search of the passenger compartment was reasonable under principles that the Supreme Court created in a prior case, Terry v. Ohio, (392 U.S. 1 (1968)). In Terry, the Supreme Court held that there was a valid protective search for weapons in the absence of probable cause to arrest because it was unreasonable to deny a police officer the right “to neutralize the threat of physical harm,” when the officer possesses a reasonable suspicion that an individual is armed and dangerous. In Terry, the Supreme Court only permitted a search of the person. In this case, the Supreme Court holds that the principles outlined in Terry also apply to the passenger compartment and trunk of a vehicle if the officer has a reasonable suspicion that a person may be armed and dangerous.
Long also tried to argue that the Michigan constitution afforded greater protection from search and seizures then the U.S. Constitution and that the reference to the state constitution in the Michigan Court’s opinion formed a basis for independent and adequate state grounds. The Supreme Court analyzed the Michigan Supreme Court’s opinion and confirmed that it referred to the state constitution, but noted that it otherwise relied exclusively on federal law. The Michigan opinion did not include a plain statement that the references to federal law were solely used as a guide, and the decision was really based on the Michigan constitution. Without such a plain statement, the Supreme Court held that the case is not based on independent and adequate state grounds, and therefore, is reviewable by the Supreme Court.

CONCLUSION

  • Advocates: Louis J. Caruso Argued the cause for the petitioner David A. Strauss Argued the cause for the United States as amicus curiae urging reversal James H. Geary Argued the cause for the respondent
  • Petitioner: Michigan
  • Respondent: Long
  • DECIDED BY:Burger Court
  • Location: Long’s Vehicle
Citation: 463 US 1032 (1983)
Argued: Feb 23, 1983
Decided: Jul 6, 1983
Michigan v. Long Case Brief