Michigan v. Long

The ruling had two results. First, it allowed police to search a detainee's car without first obtaining a warrant or placing the driver under arrest, if the officers had a reasonable fear of physical harm. Second, the Court defined a new standard for when it would review a lower court's decisions. If the lower court clearly stated it had based its decision on "adequate and independent state grounds," the Supreme Court would not take the case.

The U.S. Supreme Court had long held that its jurisdiction applies only to cases involving points of federal law. Over the years, however, some state supreme courts have based their decisions on a mixture of state and federal law, subsequently blurring the High Court's jurisdiction. When the state of Michigan asked the Supreme Court to review Michigan v. Long, the respondent, David Long, asserted the case did not belong in the Supreme Court. The Court disagreed, and in its decision it spelled out when it would hear such cases in the future.

Long's case involved his Fourth Amendment rights against unreasonable search and seizure, stemming from his conviction for possession of marijuana. Late one night, two police officers observed Long's car swerving along a Michigan country road. Long then careened off the road into a ditch, and the police investigated the scene. Long got out of his car, and the officers determined he was intoxicated. Looking inside the car, the officers saw a hunting knife. They then searched Long for weapons and looked inside the car again. One officer saw a leather pouch containing marijuana. Long was arrested, and the police then found more marijuana in the trunk.

At his trial, Long tried to suppress the marijuana as evidence, claiming the officers had made an unreasonable search of his car. Both the circuit and appeals court denied Long's claim, extending the Supreme Court's ruling in Terry v. Ohio (1968). In that case, the Court held that police can search a detainee's body for weapons before an arrest, if the officers have a reasonable fear for their safety. Now, the so-called "Terry search" was applied to a detainee's car as well.

The Michigan Supreme Court, however, agreed with Long and overturned his conviction. It cited both the Fourth Amendment and the Michigan State Constitution in defending Long's right to be free from unreasonable search and seizure. The state of Michigan then asked the Supreme Court to consider the case and it agreed, wanting to rule on the use of the Terry search on a detainee's car.