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Law School Case Brief

Michigan v. Long - 463 U.S. 1032, 103 S. Ct. 3469 (1983)

Rule:

The search of the passenger compartment of an automobile, limited to those areas in which a weapon may be placed or hidden, is permissible if the police officer possesses a reasonable belief based on specific and articulable facts which, taken together with the rational inferences from those facts, reasonably warrant the officer in believing that the suspect is dangerous and the suspect may gain immediate control of weapons. The issue is whether a reasonably prudent man in the circumstances would be warranted in the belief that his safety or that of others was in danger.

Facts:

Two police officers, patrolling in a rural area at night, observed a car traveling erratically and at excessive speed. When the car swerved into a ditch, the officers stopped to investigate and were met by respondent David Long, the only occupant of the car, at the rear of the car. Long, who "appeared to be under the influence of something," did not respond to initial requests to produce his license and registration, and when he began walking toward the open door of the car, apparently to obtain the registration, the officers followed him and saw a hunting knife on the floorboard of the driver's side of the car. The officers then stopped Long and subjected him to a patdown search, which revealed no weapons. One of the officers shined his flashlight into the car, saw something protruding from under the armrest on the front seat, and upon lifting the armrest saw an open pouch that contained what appeared to be marijuana. Long was arrested for possession of marijuana. A further search of the car's interior revealed no more contraband, but the officers decided to impound the vehicle and more marijuana was found in the trunk. The Michigan state trial court denied Long's motion to suppress the marijuana taken from both the car's interior and its trunk, and he was convicted of possession of marijuana. The Michigan Court of Appeals affirmed, holding that the search of the passenger compartment was valid as a protective search under Terry v. Ohio, 392 U.S. 1, and that the search of the trunk was valid as an inventory search under South Dakota v. Opperman, 428 U.S. 364. However, the Michigan Supreme Court reversed, holding that Terry did not justify the passenger compartment search, and that the marijuana found in the trunk was the "fruit" of the illegal search of the car's interior.

Issue:

Could a protective search for weapons extend to an area beyond the person in the absence of probable cause to arrest?

Answer:

Yes

Conclusion:

The United States Supreme Court held that articles inside the relatively narrow compass of the passenger compartment of an automobile were within the area into which a suspect might reach in order to grab a weapon. Protection of police officers justified protective searches when the officers had a reasonable belief that the suspect posed a danger, especially during roadside encounters. As such, the search of Long's vehicle was permissible since it was limited to those areas where a weapon could have been placed or hidden.

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