Michigan Dep’t of State Police v. Sitz
Citation and Court
496 U.S. 444 (1990) — Supreme Court of the United States
Facts
Michigan established a sobriety checkpoint program in which all vehicles were briefly stopped and officers looked for signs of intoxication. Sitz was stopped, found to be intoxicated, and arrested. He challenged the checkpoint program as an unconstitutional seizure without individualized suspicion.
Issue
Whether suspicionless sobriety checkpoints at which all motorists are briefly stopped violate the Fourth Amendment.
Holding
Sobriety checkpoints are constitutional; the state’s substantial interest in reducing drunk driving accidents outweighs the minimal intrusion of a brief stop under the Fourth Amendment’s reasonableness balancing test.
Rule / Doctrine
Using the Brown v. Texas three-part balancing test, the Court weighed (1) the state’s interest in preventing drunk driving (substantial), (2) the degree to which checkpoints advance that interest (meaningful), and (3) the severity of interference with individual liberty (slight). The balance favors the government, and no individualized suspicion is required.
Significance
Established sobriety checkpoints as a constitutionally permissible exception to the individualized-suspicion requirement. Later distinguished by Indianapolis v. Edmond, which prohibited checkpoints whose primary purpose is general drug interdiction.