Constitutional Law I, Pages 34–35

Michigan v. Long

1983

Facts:

Defendant was arrested for marijuana possession during a traffic stop after an officer searched his passenger compartment for weapons. This violated the Michigan state constitution, but not the federal Constitution.

Procedural History:

Michigan Supreme Court found for defendant.

Issue:

Did defendant have an adequate and independent basis for his state law defense?

Reasoning:

The Michigan Supreme Court primarily talked about federal laws in its decision. This must mean that it based its decision on federal law. However, the Fourth Amendment does not protect defendant in this situation, so federal law cannot protect him.

Holding:

No, Michigan's decision did not have a sufficiently adequate and independent state basis. Reversed.

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