Michigan v. Long
United States Supreme Court
463 U.S. 1032 (1983)
Police stopped David Long (defendant) after his car swerved into a ditch following erratic, high-speed driving. Long ignored requests for his registration and walked toward his car's open door; officers, suspecting he might be armed given his behavior, followed him and saw a large hunting knife on the driver's floorboard. A protective patdown of Long found nothing, but an officer shining a flashlight into the car saw something under the armrest, lifted it, and found marijuana; officers then arrested Long, searched the car's interior further without finding more contraband, and later found 75 pounds of marijuana in the car's trunk during an inventory search after impounding it. The Michigan Supreme Court suppressed the marijuana, ruling the interior search exceeded what Terry v. Ohio allowed, without stating whether its ruling rested on independent state grounds.
Whether the U.S. Supreme Court has jurisdiction to review a state court decision granting a defendant broader protections than the federal Constitution requires, absent an explicit statement that the ruling rests on independent and adequate state grounds; and whether a search of a car's passenger compartment is permissible when an officer reasonably believes a suspect is dangerous and may gain immediate control of weapons.