The Michigan Supreme Court addressed Fourth Amendment search protections in *People v. Armstrong*, a case involving multiple firearm charges that has implications for vehicle search procedures across the state. The court decided the case April 2, 2025, with an amended opinion issued June 3 following a motion for rehearing.
Jeffery S. Armstrong faced charges in Wayne Circuit Court for carrying a concealed weapon under MCL 750.227, being a felon in possession of a firearm under MCL 750.224f, and possession of a firearm during commission of a felony under MCL 750.227b. The charges stemmed from police discovery of a handgun under the passenger seat of a vehicle where Armstrong was sitting.
The legal dispute centers on the circumstances surrounding the discovery. Corporal Treva Eaton claimed she approached the parked vehicle because she detected the smell of marijuana emanating from it. This sensory observation became the foundation for the subsequent search that uncovered the firearm.
Armstrong's defense team moved to suppress the gun as evidence, arguing the weapon was discovered through a search that violated Fourth Amendment protections against unreasonable searches and seizures. The defense contended that the initial approach and subsequent search lacked sufficient constitutional justification.
The prosecution countered with two primary arguments defending the legality of the search. First, they argued that the marijuana odor provided sufficient probable cause to search the vehicle under established Michigan precedent from *People v. Kazmierczak*, 461 Mich 411 (2000). Second, they contended that officers lawfully observed the gun in plain view during their investigation.
The *Kazmierczak* precedent has been central to Michigan vehicle search law for over two decades. That 2000 decision established parameters for when the smell of marijuana alone can justify a warrantless vehicle search, balancing law enforcement needs with constitutional protections.
The case highlights ongoing tensions in Fourth Amendment jurisprudence, particularly regarding vehicle searches and the role of sensory evidence in establishing probable cause. Courts must balance legitimate law enforcement interests in preventing firearm crimes with constitutional protections against unreasonable searches.
For individuals with prior felony convictions, the stakes in such cases are particularly high. Michigan's felon-in-possession statute, MCL 750.224f, carries significant penalties and represents a common charge in firearm prosecutions. The concealed weapon charge under MCL 750.227 adds another layer of potential criminal liability.
The possession of firearm during commission of a felony charge under MCL 750.227b requires prosecutors to prove the defendant possessed a firearm while committing another felony. This charge often accompanies other firearm-related offenses and can result in mandatory sentencing enhancements.
The case's procedural history reflects its complexity and importance. The Michigan Supreme Court heard oral arguments on September 24, 2024, after granting leave to appeal from lower court decisions. The fact that the court issued an amended opinion in June following a motion for rehearing suggests the issues presented were particularly challenging and merited additional consideration.
Vehicle searches based on marijuana odor have become increasingly complex legal issues, especially as marijuana laws evolve across jurisdictions. Courts must navigate changing social attitudes toward marijuana while maintaining established Fourth Amendment protections.
The plain view doctrine, which the prosecution cited as an alternative justification, allows officers to seize evidence that is clearly visible during a lawful observation. However, the application of this doctrine requires that the initial police presence be lawful and that the incriminating nature of the observed item be immediately apparent.
Defense arguments in such cases typically focus on challenging the initial justification for police contact and questioning whether subsequent observations truly fall within plain view exceptions. The suppression motion in *Armstrong* reflects standard defense strategy in Fourth Amendment challenges.
The Wayne Circuit Court, where the charges were filed, handles numerous criminal cases involving firearm violations. As Michigan's largest trial court by volume, decisions from this jurisdiction often influence statewide legal practice.
The Michigan Supreme Court's ruling in *Armstrong* will likely provide guidance for law enforcement, prosecutors, and defense attorneys handling similar cases throughout the state. The decision's impact may extend beyond Michigan's borders, as other jurisdictions grapple with similar Fourth Amendment questions.
The case demonstrates the continuing importance of Fourth Amendment protections in criminal law, particularly as law enforcement techniques evolve and courts interpret constitutional requirements in new factual contexts. The amended opinion suggests the court carefully considered the balance between effective law enforcement and constitutional protections.
Going forward, the *Armstrong* decision will serve as precedent for similar vehicle search cases in Michigan courts. Legal practitioners will analyze the ruling's specific holdings and reasoning to understand its application to future cases involving comparable circumstances.