The scope of a warrantless search of an automobile is not defined by the nature of the container in which the contraband is secreted. Rather, it is defined by the object of the search and the places in which there is probable cause to believe that it may be found. Probable cause to believe that a container placed in the trunk of a taxi contains contraband or evidence does not justify a search of the entire cab.
Defendant placed a bag in the trunk of a car. Police officers stopped him, opened the trunk, and found marijuana. Defendant pled guilty to possessing marijuana for sale, but appealed the denial of his motion to suppress marijuana found in a paper bag in a car's trunk. The Court of Appeal of California, Fourth Appellate District concluded that the marijuana should have been suppressed. The State was granted certiorari.
Is a warrant necessary for the police to open the sack in a movable vehicle if they have probable cause that the container, but not the car, contains contraband?
The Court held that the Fourth Amendment did not require the police to obtain a warrant to open the sack in a movable vehicle simply because they lacked probable cause to search the entire car. The same probable cause to believe that a container held drugs allowed the police to arrest the person transporting the container and search it. The police had probable cause to believe that the paper bag in the car's trunk contained marijuana and probable cause allowed a warrantless search of the paper bag. The Fourth Amendment did not compel separate treatment for an automobile search that extended only to a container within the vehicle. The police could search containers found in an automobile without a warrant if their search was supported by probable cause. The judgment concluding that marijuana found in a paper bag in the trunk of a car should have been suppressed was reversed, and the case was remanded for further proceedings consistent with the Court's opinion.