Michigan v. Long

Michigan v. Long, 463 U.S. 1032 (1983), is a landmark decision of the United States Supreme Court.

Police officers stopped a driver for speeding and observed a hunting knife on the floorboard. They conducted a protective search of the passenger compartment and found marijuana. The driver was convicted, but the Michigan Supreme Court suppressed the evidence under the state constitution. Michigan appealed, and the U.S. Supreme Court had to determine whether its review was proper given the state-law ground.

Significance

Justice O’Connor’s 6-3 opinion established the ‘Long presumption’ for determining whether a state court decision rests on independent and adequate state grounds. The Court also held that officers conducting a Terry stop may search the passenger compartment of a vehicle if they have reasonable suspicion that the suspect is dangerous and may gain access to weapons. The ‘automobile frisk’ authorized by Long allows officers to search areas where a weapon might be hidden or quickly accessed.

Category

US Federal Case Law