Legal Studies Capstone: Federalism Case Study
Michigan Dept. of State Police v. Sitz, 496 U.S. 444, 110 S. Ct. 2481 (1990)
Sitz v. Michigan Dept. of State Police, 193 Mich. App. 690, 485 N.W.2d 135 (1993)
This case study 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 involves two related court cases that were heard in two different court systems and demonstrates some key concepts of federalism. Federalism is a system of government in which a country, such as the United States, is controlled by two levels of government: An overarching national (federal) government that is responsible for broader governance, and individual state governments that govern issues of state and local concern. The U.S. Constitution established this dual system of government, under which the states surrendered many of their powers to the federal government, but also retained some autonomy. The federal government and each of the state governments consist of three branches (legislative, executive, and judicial) responsible for enacting, enforcing, and interpreting laws.
This case study demonstrates how a case involving a state legal issue can make its way into the federal court system. It also provides examples of the types of cases that each court system handles and 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, here are some 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 U.S. 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, however, provide a “ceiling,” that state courts may not go above.
Facts
Michigan Dept. of State Police v. Sitz, 496 U.S. 444, 110 S. Ct. 2481 (1990)
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 (MDP) 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 police in this matter was a man named Rick Sitz. The Michigan trial court ruled in the drivers’ favor. The Michigan Court of Appeals affirmed the trial court’s decision.
The MDP 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 of the U.S. Constitution. 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 Dept. of State Police, 193 Mich. App. 690, 485 N.W.2d 135 (1993)
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.
INSTRUCTIONS: Answer all of the questions in order, in the below question sets. Answers should be typed in a minimum 12-point font. Answers should not be bolded. This is an individual assignment. Please ask the professor if you have any questions.
Question Set #1 – Use the case study information provided above. You may also do Internet research to supplement your answers but make sure to include URLs with your answers and not just copy and paste chunks of material. Edit answers and put them in your own words.
1. Describe the structure of the Michigan court system as it appeared in this case. Compare Michigan’s state court system structure to Georgia’s state court system structure.
2. What is the wording of the 4th amendment of the U.S. Constitution regarding searches and seizures? (For this answer, you should copy the exact wording of the amendment.)
3. Why was the U.S. Supreme Court able to hear this case?
4. 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?
5. What is the concept of federalism? How does this case illustrate the concept of federalism in the American judicial system? If you didn’t already address this in an above answer, explain the “floor” and “ceiling” concept raised by this case.
Question Set #2 – Do Internet research and make sure to include the URLs with your answers and not just copy and paste chunks of material. Law firm websites in Georgia are a great resource! Edit answers and put them in your own words.
1. How many states currently permit sobriety checkpoints? Is Georgia one of the states that permit sobriety checkpoints?
2. What other types of roadblock checkpoints are also permitted in Georgia?
3. In Georgia, what are the requirements that must be established for the state to set up roadblocks that are constitutionally compliant? (For these factors, you may copy and paste the actual language of each requirement). List each one separately below and identify each with a bullet point or other delineation:
Question Set #3 – Use Westlaw Campus Research to look up and read
State v. Connor, 322 Ga. App. 636, 745 S.E.2d 837 (2013).
To access Westlaw Campus Research, go to the CSU library homepage, under Galileo click on W and then select Westlaw Campus Research. Ask your instructor if you can’t remember how to access Westlaw.
1. According to the Connor decision, which one of the above requirements was at issue?
2. Did the Court of Appeals in Connor affirm or reverse the trial court’s ruling to suppress evidence obtained at the checkpoint? On what basis did the appellate court make this decision?
Question Set #4 – Use Westlaw Campus Research to look up and read
Thomas v. State, 277 Ga. App. 88, 625 S.E.2d 455 (2014).
1. According to the Thomas decision, which one of the above requirements was at issue?
2. Did the Court of Appeals in Thomas affirm or reverse the defendant’s conviction? On what basis did the appellate court make this decision?
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