In the 1982 case Michigan v. Long, the U.S. Supreme Court ruled that when police officers have probable cause to believe that a vehicle contains weapons potentially dangerous to the officers, they may conduct a Terry-type search of those compartments in which a weapon could be placed or hidden. The case involved David Long who was stopped by two sheriff's deputies for erratic driving and subsequently arrested for possession of marijuana found during an investigatory search of his car’s interior compartment after observing him exit from his moving vehicle appearing under influence and noticing a large hunting knife on floorboard inside open door. The Michigan Supreme Court reversed this decision stating Fourth Amendment required suppression of evidence as there were no specific facts justifying fear for officer safety warranting protective sweep beyond person into areas within immediate control like passenger compartment here where suspect can gain possession of weapon or destructible evidence but US Supreme court disagreed with them holding such searches permissible if police possess articulable suspicion individual is potentially dangerous.

In the dissenting opinion for Michigan v. Long, Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority had unnecessarily expanded police powers in a way that threatened Fourth Amendment protections against unreasonable searches and seizures. They contended that there was no evidence to suggest Terry stops (brief detentions based on reasonable suspicion of criminal activity) were insufficient for ensuring officer safety during traffic stops. The dissent also criticized the majority's decision to review a state court case where it wasn't clear if the ruling was based on federal or state law grounds; they believed this violated principles of federalism by intruding upon states' rights to interpret their own laws independently from federal interpretation. Overall, they felt this case represented an unwarranted extension of judicial power into matters better left to individual states.