A sheriff's deputy received a tip from a reliable confidential informant that respondent had gone to New York to buy drugs and would return later that day to Maryland in a rented red Toyota with a large quantity of cocaine. The deputy confirmed that the reported license plate belonged to a red Toyota Corolla rented to respondent, who was known in St. Mary's County as a drug dealer. When respondent returned in the rented car, deputies stopped and searched it without a warrant. They found 23 grams of crack cocaine in a duffel bag in the trunk.
Issue
Does the Fourth Amendment require police to obtain a warrant before searching a vehicle when they have probable cause to believe it contains illegal drugs, unless there is also a separate exigency making it impracticable to obtain a warrant?
Rule
Under the automobile exception to the Fourth Amendment's warrant requirement, police may search a readily mobile vehicle without a warrant when they have probable cause to believe it contains contraband or evidence of a crime. The exception does not require a separate showing of exigency beyond probable cause.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, a narcotics detective received a tip from a confidential informant who had previously given accurate information that Lena Ortiz would be driving a gray Honda Accord from Tucson to Phoenix that evening with methamphetamine hidden somewhere inside the car. The detective confirmed that the plate number given by the informant matched a gray Accord registered to Lena, waited until the car arrived, and searched it without first seeking a warrant, even though the detective had several hours earlier in the day to apply for one.
If a court finds the officers had probable cause to believe the car contained contraband and the car was readily mobile, is the warrantless search constitutional?
Explanation. The controlling rule is that police may search a readily mobile vehicle without a warrant when they have probable cause to believe it contains contraband or evidence of crime. No separate showing of exigency is required, so the fact that officers had time to seek a warrant does not by itself invalidate the search. (Derived from Maryland v. Dyson (n.d.).)