Michigan Department of Police v. Sitz
496 U.S. 444 (1990)
Sitz v. Michigan Department of Police
193 Mich. App 690 (1993)
The judges and court volunteers will guide students through the case of Michigan Department of Police v. Sitz. This case explores (1) the nature of the two court systems (federal and state) that make up the American judicial system and (2) how they interact with each other.
Introduction
This case study provides an actual case to serve as the basis for examining the differences, similarities, and interactions between the federal and state court systems. These cases demonstrate many of the key concepts that this lesson teaches. Among other things, it demonstrates how a case involving a state legal issue can make its way into the federal court system. It also provides examples of the cases that each court system handles. In addition, it demonstrates that while the U.S. Supreme Court is the final arbiter of the U.S. Constitution, the individual state supreme courts are the final arbiters of their respective state constitutions.
As the facts of the case are presented, one should be aware of the following key concepts:
Key Concepts
- Sobriety checkpoints are established to help law enforcement agencies combat DUI (driving under the influence) and DWI (driving while intoxicated).
- Both DUI and DWI are state crimes that are tried in and punished by state courts.
- The Fourth Amendment to the United States Constitution prohibits "unreasonable search and seizures."
- Through judicial interpretation of the 14th Amendment of the U.S. Constitution, most of the provisions of the federal Bill of Rights have become incorporated (or made applicable) to the states.
- The state courts can interpret the U.S. Constitution subject to final review by the U.S. Supreme Court.
- Federal courts cannot interpret state constitutions or state law.
- This case went before both the U.S. Supreme Court and the Michigan Supreme Court.
- Federal constitutional law provides a "floor" for individual rights that state courts may not go below. It does not provide a "ceiling" that state courts may not go above.
Facts of the Case
Michigan Department of Police v. Sitz
There are actually two separate cases involved in this case study, though both have the same parties, issues, and set of facts. The first case is known as Michigan Department of Police v. Sitz. This case was a civil (not criminal) class action suit. It arose when the Michigan Department of Police began using random sobriety checkpoints on state roads in an attempt to crack down on drinking and driving. Litigation was initiated by a group of licensed drivers. The drivers alleged that such checkpoints violated the Fourth Amendment's prohibition against "unreasonable searches and seizures." The named party in the class action suit that sought to stop the actions of the Michigan State Police in this matter was a man named Rick Sitz. The trial court ruled in the drivers' favor. The Michigan Court of Appeals affirmed the trial court's decision.
The Michigan Department of Police then appealed to the Michigan Supreme Court. When the Michigan Supreme Court refused to hear the case, the police petitioned the U.S. Supreme Court for a writ of certiorari to review the Michigan Court of Appeals' interpretation of the Fourth Amendment. The U.S. Supreme Court granted the police department's request and agreed to hear the case. Since the U.S. Supreme Court acknowledged that the sobriety checkpoints did constitute a "seizure" within the meaning of the Fourth Amendment, the only question for the Court to resolve was whether the "seizure" was "unreasonable."
Writing for the majority, Chief Justice Rehnquist stated that "... the State's interests in preventing drunken driving, the extent to which this system can reasonably be said to advance that interest, and the degree of intrusion upon the individual motorists who are briefly stopped, weighs in favor of the state program." The U.S. Supreme Court concluded that the Michigan Court of Appeals erred in saying that the sobriety checkpoints violated the Fourth Amendment. The U.S. Supreme Court reversed the decision of the lower court and remanded (sent back) the case to that court with instructions to act in a manner consistent with the U.S. Supreme Court's opinion.
Sitz v. Michigan Department of Police
After losing in the federal courts, the licensed drivers of Michigan continued to pursue their suit in the Michigan state court system. This time, they alleged that the sobriety checkpoints violated Article 1, Section 11, of the Michigan Constitution, which also prohibited "unreasonable searches and seizures." On remand from the U.S. Supreme Court, the Michigan Court of Appeals recognized that while the checkpoints did not violate the Fourth Amendment to the U.S. Constitution, it agreed with the drivers and held that the checkpoints did violate the Michigan Constitution. When the case came before it, the Michigan Supreme Court affirmed the Michigan Court of Appeals' decision saying that:
... [the] Constitutional liberties include the right to travel, and automobiles generally may not be searched absent probable cause. In this case, the state police erected sobriety checkpoints along state highways, at which all vehicles were required to stop. While stopped, the drivers were briefly inspected by officers for signs of intoxication, and permitted to resume their travels if no signs were detected. This warrantless, suspicionless stop of vehicles for the purposes of criminal investigation violated the Michigan Constitution."
Furthermore, the court tried to reconcile its decision with the U.S. Supreme Court's decision in this matter by stating that federal constitutional law provides a "floor" for state court litigation, and while "...state judges must not adopt state constitutional rules which fall below this floor; courts may, however, appeal to the relevant state constitution to establish a higher 'ceiling' of rights for individuals." In other words, the Michigan Supreme Court found that the Michigan Constitution provided a higher "ceiling" for individual rights than did the U.S. Constitution in this particular case.
Discussion Questions
The following are examples of some questions that may be asked to see if the students understand the case study. The judges and courtroom coordinators should feel free, and are encouraged, to add more.
- Describe the structure of the Michigan court system as it appeared in this case. How much does it represent the "typical" court system presented in this lesson?
The Michigan court system has a trial-level court; an intermediate appellate court, called the Michigan Court of Appeals; and the state's highest court, called the Michigan Supreme Court. The Michigan Supreme Court has discretionary review, which means that it decides which cases to hear. This court system is similar to the typical system presented in this lesson. No courts of limited jurisdiction were mentioned in this case.
- Why was the U.S. Supreme Court able to hear this case?
The drivers who brought this case alleged that it violated their Fourth Amendment right against "unreasonable searches and seizures." The 14th Amendment to the U.S. Constitution incorporated (applied) the 4th Amendment's protections to the states. Since the state court interpreted this provision of the federal Constitution, it subjected itself to review by the U.S. Supreme Court.
- How could the same issue be raised again in a state court if the U.S. Supreme Court had already ruled on it? In saying that the sobriety checkpoints violated the Michigan Constitution, did the Michigan Supreme Court overrule the U.S. Supreme Court? Can this be done?
Although the facts of the case had not changed, the legal arguments did. When the case came before the U.S. Supreme Court, the drivers argued that the sobriety checkpoints violated the Fourth Amendment to the U.S. Constitution. When the Court said there was no constitutional violation, the drivers challenged the action in state court. This time, they alleged a violation of the Michigan Constitution, which also prohibited "unreasonable searches and seizures."
The Michigan Supreme Court ultimately concluded that the sobriety checkpoints did violate the Michigan Constitution. Since the Michigan Supreme Court was interpreting solely the state's constitution, it did not overrule the U.S. Supreme Court. A state court cannot overrule the U.S. Supreme Court when the court has interpreted a provision of the federal Constitution, a federal statute, treaty, etc. In fact, if the U.S. Supreme Court has spoken on a constitutional issue, only a constitutional amendment or subsequent decisions of the Court can change it. If it has spoken on a statute, an act of Congress may be sufficient to change it.
- What does this case say about the American judicial system?
This case is an example of how the federal and state court systems interact with each other. Both the federal Constitution and the Michigan Constitution came into play. The case showed how the federal courts are the final arbiters of federal law; the U.S. Supreme Court being the ultimate arbiter. However, it also showed how the state courts have vast powers when dealing with matters reserved to their sphere, such as state constitutional law. It demonstrated that the federal courts often provide a "floor" for citizens' rights that state courts may not go below. Moreover, it also showed how state courts can, and do, raise the "ceiling" for some of these rights.
Activity: Can You Make a Federal Case Out of It?
In this activity, students will be given the facts of a case and asked whether the case belongs in federal or state court. After this, for applicable state cases, students will be referred to an appropriate constitutional provision and asked how they can "make a federal case out of it." For example, in the case of Gideon v. Wainwright, the student will be told that the defendant was accused of breaking and entering; however, he was indigent (without resources) and was denied the assistance of counsel when he asked for it at his trial. The student should respond that the breaking and entering is a state offense that is handled by the state court system. However, since the defendant was denied his Sixth Amendment right to counsel, the federal courts could also hear his appeal.
1. Gideon v. Wainwright (state and federal)
Facts: The defendant, Clarence Earl Gideon, was alleged to have broken into a pool hall with the intent to commit a misdemeanor once inside. This led to his being charged with the felony of breaking and entering. He was subsequently arrested, tried, convicted, and sentenced to a prison term of five years. However, Gideon was also indigent (without funds) and was not able to afford an attorney. He asked the trial judge to assign him an attorney for free, saying that such action is required by the Sixth Amendment to the U.S. Constitution. However, the trial judge stated that the Sixth Amendment did not require such action to be taken in this case and denied his request.
Which court system (state or federal) would have handled Gideon's case for the crime of breaking and entering? Why?
Most crimes are a matter of state law. Breaking and entering is an example of a crime that is left to the states to define and punish. Therefore, a state court would have handled this case. The Florida courts did so in real life.
Note: Provide students with a copy of the Sixth Amendment.
How did this case reach the federal courts?
The Sixth Amendment to the U.S. Constitution states in pertinent part:
"In all criminal prosecutions, the accused shall...have the Assistance of Counsel for his defense.
Since the "due process" clause of the 14th Amendment was being used to incorporate many provisions of the Bill of Rights to the states, Gideon argued that the state trial court's denial of his petition for an attorney free of charge violated his Sixth Amendment right to the assistance of counsel for his defense. The state trial court ruled against Gideon and found no violation of the Sixth Amendment. Since a state court ruled on an issue of federal law, this allowed the U.S. Supreme Court to review the case after the Florida Supreme Court had finished with it. In real life, the U.S. Supreme Court sided with Gideon.
2. Bell v. Burson (state and federal)
Facts: A certain law stated that uninsured motorists who were involved in an accident would automatically have their licenses suspended. The law did not provide an opportunity for a hearing to determine whether the uninsured motorist was at fault before suspending his/her license. Paul Bell was an uninsured motorist whose license was suspended when he was involved in an accident. He claimed that he was not at fault and argued that the law in question violated his constitutional rights by depriving him of his license without "due process of law." In this context, "due process of law" basically means "fair play"—that is, fairness would demand that his license not be suspended until he was given the opportunity to be heard and present his side of the story. The trial court said his constitutional rights were not violated.
Which court system (state or federal) usually hears cases concerning traffic regulations, such as, in this case, the suspension of a driver's license? Why?
Most issues concerning traffic regulations (such as licensing drivers or suspending their licenses) are matters left to the states. Therefore, the state courts have the primary responsibility for dealing with these types of cases. In this case, the Georgia courts upheld the state law and said that the state could suspend Paul Bell's license without providing a hearing to determine if he was at fault.
Note: Refer to Section I of the 14th Amendment to the U.S. Constitution.
How did this case reach the federal courts?
Section I of the 14th Amendment to the U.S. Constitution states in pertinent part:
"... nor shall any State deprive any person of life, liberty, or property, without due process of law..."
The text of the 14th Amendment states that no state shall deprive a person of life, liberty, or property without due process of law. Since the Georgia courts interpreted this constitutional provision by holding that Bell's "due process" rights were not violated, they subjected themselves to review by the U.S. Supreme Court. The U.S. Supreme Court ultimately sided with Bell in real life.
3. The Scotia (federal) In the early 1800s, an American sailing vessel, the Berkshire, and a British sailing vessel, the Scotia, collided on the high seas. The owners of the Berkshire claimed that the Scotia was at fault and sought indemnification (payments for losses) from the owners of the Scotia. The British owners sued in an American court. The owners of the Scotia countered that the Berkshire was responsible for the collision because it failed to adhere to generally accepted principles of international law that require ships to alert others of their position. Since this case involves issues arising on the high seas and between ships, it is an admiralty case.
Which court system (state or federal) has jurisdiction over admiralty cases such as the one involving the Scotia? Why?
The Constitution gives the federal courts exclusive jurisdiction over admiralty cases. Therefore, the federal courts had jurisdiction over this case. In real life, the U.S. Supreme Court found that since the Berkshire failed to adhere to applicable standards of international law designed to avoid collisions, the owners of the Scotia would not have to indemnify the owners of the Berkshire for any losses that it sustained.
4. United States v. General Dynamics Corporation (federal)
Facts: Monopolies arise when a company dominates the market in its line of business. Due to various laws, most monopolies have been outlawed in the United States. One law goes further than simply outlawing monopolies; it also prohibits mergers when the effect of such an action would be to "substantially lessen competition" (allow the merging companies to gain a monopoly in their line of business). However, the law in question failed to define the term "substantially lessen competition." When two companies, each controlling a substantial portion of the coal industry, decided to merge, the government intervened and sued in court to prevent the merger. The government argued that the merger violated the law because (1) the merged firm would control an "undue percentage share" of the relevant market and (2) the merger resulted in a significant increase "in concentration in the relevant market." General Dynamics countered that the effects of the merger had to be viewed within the context of the industry, not from some objective standard. Thus, the merger would not be illegal because the context of the industry would show that the merger was justified and did not "substantially lessen competition."
Which court system (state or federal) usually hears cases involving violations of antitrust statutes such as the one, in this case, that General Dynamics Corporation was accused of violating? Why?
The federal courts preempt the state courts in matters of antitrust law. As a result, the federal courts usually hear antitrust cases. Most antitrust cases are brought under federal statutes such as the Sherman Antitrust Act or the Clayton Act. In this case, the U.S. Supreme Court sided with General Dynamics Corporation and stated that the Clayton Act does not necessarily prevent mergers between two or more companies that control large portions of a market if their intention is not to "substantially limit competition." Other factors, such as "functionally viewing" actions in the context of the industry in which they were undertaken, also should be considered.
5. Illinois v. Wardlow (state and federal)
Facts: A man named Wardlow lived in Chicago. Due to large-scale drug trafficking, the area where Wardlow resided was regarded by the police as a high-crime area. While walking one day, Wardlow saw two police officers engaged in a raid in the local neighborhood. At this point, Wardlow fled and the police chased him. Upon catching him, they frisked him for weapons and found an unregistered handgun. He was charged with carrying an unregistered handgun and brought to trial. At his trial, he argued that the frisk violated his Fourth Amendment right against "unreasonable searches and seizures," since the police never had any suspicion that he engaged in any illegal activity. The police countered that his flight gave them the necessary level of suspicion for purposes of allowing them to frisk him for weapons.
Which court system (state or federal) usually handles most criminal matters, including, in Wardlow's case, possessing an unregistered handgun? Why?
The U.S. Constitution does not give the federal government blanket authority to define and punish crimes. The federal government may define and punish only those offenses arising out of a power granted by the Constitution. This leaves the states in a position to define and punish most crimes, including many crimes concerning handguns. Therefore, this case would be handled in a state court system. In real life, the Illinois courts handled this case, the trial court ruling that the frisk was justified and did not violate Wardlow's Fourth Amendment rights.
Note: Refer to the Fourth Amendment.
How did this case reach the federal courts?
The Fourth Amendment states in pertinent part:
"The right of people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated..."
Since the "due process" clause incorporates most of the provisions of the Bill of Rights (including the provisions of the Fourth Amendment) to the states, it can be argued that the trial court erred in holding that the frisk did not violate Wardlow's Fourth Amendment rights. Since the trial court ruled on a matter of federal law, the U.S. Supreme Court could ultimately review the case. What is unique in this case is that Wardlow won on appeal in the state courts. Both the Illinois Court of Appeals and the Illinois Supreme Court reversed the trial court and held that Wardlow's Fourth Amendment rights had been violated. However, Wardlow was not yet free. Since these courts interpreted the U.S. Constitution, their interpretations were still subjected to ultimate review by the U.S. Supreme Court. The State of Illinois appealed to the U.S. Supreme Court and claimed that the Illinois appellate courts erred in their interpretation of the Fourth Amendment. The U.S. Supreme Court heard the case and overruled the Illinois appellate courts. It held that flight from the police does satisfy the Fourth Amendment's "reasonableness" requirements with regard to conducting a frisk for a weapon.
6. Orr v. Orr (state and federal)
Facts: A law concerning divorce permitted alimony orders (court orders mandating the payment of support to a former spouse) to be entered against only males, meaning only former wives could receive alimony payments. After a divorce suit, a court ordered a former husband to pay alimony to his ex-wife. When he refused to do so, the ex-wife sued to have the alimony enforced. At this point, the man claimed that the law requiring only males to make alimony payments violated the "equal protection" clause of the U.S. Constitution, because men with financial hardships would not be able to receive alimony awards.
Which court system (state or federal) would usually handle matters concerning divorce and alimony? Why?
Issues concerning marriage, divorce, and alimony are left up to the states, and the state courts are responsible for hearing such cases. In fact, state courts of limited jurisdiction, usually known as family courts, are primarily responsible for hearing these cases. The Alabama state court system heard this divorce case in real life. It said that the state's alimony law did not violate the 14th Amendment's "equal protection" clause.
Note: Refer to Section I of the 14th Amendment to the U.S. Constitution.
How did this case reach the federal courts?
Section I of the 14th Amendment to the U.S. Constitution provides in pertinent part:
"... nor shall any State...deny to any person within its jurisdiction the equal protection of the laws."
Since the state courts in Alabama interpreted the federal Constitution, they subjected themselves to review by the U.S. Supreme Court. The U.S. Supreme Court agreed with the ex-husband in this case and said that alimony laws requiring only males to pay alimony violated the 14th Amendment's "equal protection" clause.
7. McPherson v. Buick Motors Company (state)
Facts: This is an example of a case involving tort law (torts are cases that deal with injuries occurring between two private parties). This case arose out of an injury that Donald C. McPherson sustained from a car manufactured by Buick Motors Company. He sought monetary damages to compensate him for his injury. However, Buick Motors Company claimed that (1) it did not intend to injury McPherson and (2) it did not sell the defective car directly to him. The company sold the car to a retailer who in turn sold it to McPherson. Therefore, Buick Motors argued that it could not be held liable under any existing system of tort law because (1) it did not commit an "intentional tort," and (2) it did not commit a tort of "negligence" since there was no causation (direct interaction) between the company and McPherson. On appeal, McPherson argued that the court should use its common-law powers to hold manufacturers responsible for defective products they produce regardless of their intent to harm or the causation between the parties. The appellate court agreed.
Which court system (state or federal) hears most tort and personal injury cases? Which courts (state or federal) have common-law powers to create law or fill gaps in existing law to reach an equitable solution to a given legal problem, such as the one mentioned in this case?
The answer to both of these questions is the state court system. In general, torts are a matter that the U.S. Constitution reserves to the states and to their courts. Furthermore, the authority of courts to use their common-law powers to make or fill gaps in the law for equitable reasons is a sole prerogative of the state courts. The federal courts have no such right with regard to their power to hear cases involving federal questions. They do, however, have some common-law powers when hearing diversity of citizenship cases because, in these cases, they are applying state law. This case is well known because it established the principle in tort law of allowing manufacturers to be held responsible for their defective products even in the absence of intent to cause harm or causation. This is known as the principle of "strict liability." The federal courts were not involved in this case.
8. Lucy v. Zehmer (state)
Facts: This case involves contract law. For courts to find contracts binding, six elements must be present. One of these elements is called an offer, meaning some one offers to do, or refrain from doing, something—for example, an offer to sell a house. For an offer to be made, the person making the offer must intend to make it. Some courts use a "reasonable person" standard to determine whether an offer was made. The "reasonable person" standard asks whether a reasonable person would assume that the person making the offer had an intent to enter into a contractual relationship. In this case, two people, W.O. Lucy and A.H. Zehmer, had a few drinks together. During the course of the evening, Lucy made an offer to buy Zehmer's farm. Zehmer accepted the offer, and Lucy made the necessary legal and financial arrangements. Regretting what he had done, Zehmer tried to back out of the contract. He said that he had not accepted Lucy's offer because he thought that Lucy had made it in jest. Lucy countered that he had made a reasonable offer for the property. He said that although both persons were drinking at the time, Zehmer did not appear to be intoxicated when the offer was made; therefore, Lucy took him at his word. Furthermore, since Lucy had already made several provisions concerning the sale, he would not let Zehmer back out. The parties went to court to determine whether an offer actually existed. The court found that Lucy had made a legitimate offer that Zehmer had accepted.
Which court system (state or federal) usually handles matters concerning contract law, such as, in the current case, determining if an offer has been made? Why?
Contract law is another area of law that is left primarily to the states. Therefore, cases involving contracts are usually handled in state courts. Furthermore, since the subject of the contract in this case involves a subject, real property, which is another prerogative of the states, the state courts would certainly have jurisdiction over this case. Occasionally, though, federal courts also have jurisdiction over cases involving contracts. This usually occurs when one of the parties to the contract is the federal government.
9. New Jersey v. New York (federal)
Facts: Part of the boundary between the states of New York and New Jersey runs along Ellis Island (an island off the shore of Manhattan). When new land formed near the island due to accretion (steady buildup of sediments and deposited soil), both New York and New Jersey laid claim to it. When the states failed to reach a satisfactory agreement as to which state the new land belonged to, the states brought the matter to court.
Which court system (state or federal) would have handled this case? Why?
Legal cases arising between two or more states are always heard in the federal court system. Furthermore, the U.S. Supreme Court has original jurisdiction over these cases. This means that the U.S. Supreme Court is the only federal court that may hear them.
10. Other applicable cases (cases that the judge or courtroom coordinators feel would serve as good examples).