United States v. Lopez (2004)

United States Court of Appeals for the First Circuit · 2004 · Evidence

380 F.3d 538 (1st Cir. 2004)

Updated August 22, 2026

EvidenceFourth AmendmentMirandaAutomobile exceptionCustodial interrogationwarrantless vehicle searchprobable causehidden compartment

Facts

Police and DEA agents surveilled a series of arranged crack cocaine transactions involving Lopez and Terri Tremblay, culminating in Lopez's arrest in a minivan during a planned buy. At the scene, officers recovered most of the serialized buy money, received Tremblay's statement that Lopez had brought more crack than she planned to purchase, and had a drug dog repeatedly alert near the front passenger seat, but they did not initially find the drugs. Officers moved the van to the police station and continued searching, where they found a locked hidden compartment under the passenger seat containing crack cocaine, a loaded handgun with an obliterated serial number, and photographs bearing Lopez's name. After Lopez had requested an attorney, an agent briefly told him they had found "the stuff" and that "the deal was off," after which Lopez made incriminating remarks to the officer supervising him.

Issue

Whether the warrantless search of Lopez's van at the police station was lawful under the automobile exception because officers had probable cause to believe it contained contraband. Whether Lopez's post-arrest statements were inadmissible under Miranda because they were the product of custodial interrogation after he requested counsel.

Rule

Police may conduct a warrantless search of an automobile, including containers and hidden compartments within it, when they have probable cause to believe the vehicle contains contraband. Miranda bars only statements stemming from custodial interrogation or its functional equivalent; voluntary statements are admissible, and the functional equivalent of interrogation consists of words or actions police should know are reasonably likely to elicit an incriminating response.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Providence, Rhode Island, narcotics officers monitored three arranged methamphetamine sales between Nolan Reyes and a cooperating buyer over two weeks. During the fourth planned buy, officers arrested Nolan in his SUV, recovered marked cash from the center console, heard the buyer say Nolan had brought extra meth he had not yet handed over, and watched a trained dog alert repeatedly at the rear floorboard.

Officers tow the SUV to the station because traffic is backing up on the street and continue searching there without a warrant. Is the search most likely valid?

Explanation. The governing rule is that police may conduct a warrantless automobile search when they have probable cause to believe the vehicle contains contraband. Here, the repeated controlled sales, marked money, the buyer's statement that extra drugs remained, and the dog alert together support probable cause. Under the majority opinion, probable cause is assessed based on what officers knew at the time of the search, and relocating the car to the station does not dissipate probable cause.