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.
David Long was convicted of possession of marijuana by a Michigan Circuit Court after the court denied Long’s motion to suppress marijuana seized from his car. Long swerved his car into a ditch, and two officers had stopped to investigate the incident. The officers observed a knife on the floorboard of the driver's side of the car and subjected Long to a frisk. An officer shined his flashlight into the interior of the vehicle to search for other weapons and noticed that something was protruding from under the armrest on the front seat. After lifting the armrest, the officer saw an open pouch on the front seat containing marijuana. Long was then arrested, and the officers found more marijuana in the trunk. On appeal, the Michigan Court of Appeals affirmed Long’s conviction. However, the Michigan Supreme Court reversed, holding the search invalid.
Can a protective search for weapons extend to an area beyond the person in the absence of probable cause to arrest?
The Court held that a protective search of the passenger compartment of an automobile, limited to those areas in which a weapon may be placed or hidden, is permissible during an investigative detention if the police officer reasonably believes that the suspect is dangerous and may gain immediate control of weapons. Protection of police officers justified protective searches when the officers had a reasonable belief that the suspect posed a danger, especially during roadside encounters. Moreover, the 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.