The "automobile exception" in Michigan law allows police to search a vehicle without a warrant if they have probable cause to believe it contains evidence of a crime.This exception is grounded in the idea that vehicles are inherently mobile, meaning evidence could be...

Michigan Supreme Court – Forfeiture of 2006 Saturn ION
FORFEITURE OF 2006 SATURN ION
Michigan Supreme Court Ruling – July 25, 2025
The Michigan Supreme Court has ruled that Detroit police can no longer seize cars through civil asset forfeiture unless they can demonstrate that the vehicle was used for drug trafficking.
The court ruled that Stephanie Wilson’s 2006 Saturn Ion was not subject to forfeiture laws as there was no evidence of drug-related activities when seized in 2019. Mere proximity to suspected drug crimes or passenger drug possession is not sufficient for seizure.
Michigan Supreme Court: Factual and Procedural History
On June 24, 2019, claimant Stephanie Wilson was driving in the defendant vehicle with Malcolm Smith in the passenger seat when she was pulled over by Sergeant Chivas Rivers of the Wayne County Sheriff’s Office. Sergeant Rivers testified at his deposition that he had been surveilling a house on Lumley Street in Detroit for narcotics activity when he saw claimant and Smith drive up and park in front of that house. An unidentified man approached the passenger side of the defendant vehicle and reached his arm in through the window for what Sergeant Rivers believed to be a hand-to-hand drug transaction.
After claimant drove away, Sergeant Rivers followed the defendant vehicle a short distance before effectuating a traffic stop on the basis of a failure to signal a turn. Sergeant Rivers
testified that, when he pulled claimant over, she stated that she had driven Smith to the Lumley Street address to purchase drugs. Claimant has denied saying this.
After speaking to claimant and Smith, Sergeant Rivers searched the defendant vehicle and found five empty syringes under the passenger seat but no other evidence of drugs. Although Sergeant Rivers averred that Smith stated that he had already used the syringes to inject heroin, it appears that the syringes were never tested for drug residue. Sergeant Rivers seized the
defendant vehicle. Nearly four months later, the state initiated forfeiture proceedings pursuant to MCL 333.7521.
Following discovery, claimant moved for summary disposition on three bases:
(1) MCR 2.116(C)(7) (plaintiff failed to promptly file its complaint for forfeiture);
(2) MCR 2.116(C)(8) (plaintiff failed to state a claim on which relief could be granted); and
(3) MCR 2.116(C)(10) (there was no material factual dispute, and claimant was entitled to judgment as a matter of law).
The trial court held a hearing and considered arguments from both parties regarding the facts surrounding the seizure of the defendant vehicle.
Finding that Sergeant Rivers appeared to have witnessed a hand-to-hand transaction but that such an interaction would not necessarily involve drugs, the trial court granted summary disposition to claimant without explicitly specifying the ground on which the ruling was based.
Plaintiff filed a motion for reconsideration, a motion to stay, and an ex parte motion for relief from judgment.
The trial court denied these motions and directed plaintiff to release claimant’s vehicle immediately.
Read the Entire Opinion Here
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