Michigan v. Long Case Brief Summary | Law Case Explained
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Michigan v. Long | 463 U.S. 1032 (1983)
Terry versus Ohio permits a police officer to frisk a lawfully stopped suspect when the officer has reasonable suspicion that he or she is armed and dangerous. But can the officer also search for weapons inside the suspect’s car? The United States Supreme Court addressed this question in Michigan versus Long.
After midnight, two sheriff deputies approached David Long’s car after they observed him drive into a ditch. Long met the deputies outside the car. Based on Long’s erratic driving and odd behavior, the deputies believed that he was under the influence of drugs or alcohol. They asked Long to produce his driver’s license and the vehicle’s registration papers. Long only offered his driver’s license. After the deputies repeated their request for the vehicle’s registration, Long walked toward the driver’s door, which he had left open when he exited.
The deputies accompanied Long. Looking inside the car, the deputies observed a large knife on the floorboard. They stopped Long from going into the car and patted down his outer clothing to determine if he was armed with any other weapons. After finding no weapons on him, one of the officers, Deputy Howell, shined his flashlight into Long’s car to see if there were any other weapons. Howell saw an object protruding from under the armrest. Howell entered the vehicle and lifted the armrest, revealing a leather pouch containing marijuana. The deputies arrested Long and impounded his vehicle. A subsequent search of the car’s trunk revealed an additional 75 pounds of marijuana.
Long was charged with possession of marijuana. He filed a motion to suppress the marijuana found under the armrest and in the trunk, which the trial court denied. After Long was convicted, he appealed to the Michigan Court of Appeals, which affirmed his conviction. On further appeal, the Michigan Supreme Court held that Deputy Howell’s search of the car for weapons violated the Fourth Amendment. The Michigan Supreme Court’s opinion primarily cited case law interpreting the Fourth Amendment but also cited the Michigan Constitution’s provision prohibiting unreasonable searches. The State successfully petitioned the United States Supreme Court to review the case.
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