Facts: The
police stopped the car in which Ms. Coates rode in the backseat. The
police patted down the driver, claimed the 16 year-old 'consented' to the pat
down (reason for the stop was a minor traffic offense), and supposedly found one pill of Xanax in the 16 year-old's pocket. After the discovery,
the police ordered everyone out of the car, interrogated Ms. Coates, and
searched both the passenger compartment and the trunk of the car. In the trunk, the police claimed to find a bottle of pills. Ms. Coates
admitted to owning the car, but denied knowledge of the pills in the trunk. The
defense moved to suppress all the evidence found in the trunk, and the trial
court granted the motion. The trial court cited two bases for suppression. The
trial court stated that the police possessed neither reasonable suspicion to
search the trunk (search incident) nor probable cause to search the trunk for
contraband. The prosecution appealed the order.
Issue: Whether
the police, who found a pill of Xanax in the pocket of the driver, possessed
probable cause to search the trunk?
Held: No.
Reasoning: As
astonishing as the holding, Justice Coates wrote the decision with nary a
dissenter. First, the Court put to
rest any fantasies cops and prosecutors have about using search incident
to justify a general search of the entire car. The Court flat out stated in the
beginning of its decision, "Because the evidence for which suppression was
sought was not seized from the passenger compartment of the defendant’s
vehicle, the search-incident-to-arrest exception could not justify its seizure
under any circumstances." Arizona v.
Gant, 556 U.S. 332, ---,129 S.Ct. 1710, 1719 (2009).
The
Court then held that ticketing the driver for driving without a license and
finding a Xanax pill in the driver's pocket did not amount to probable cause to search
the trunk of the car.
Link to People v. Coates here
Link to People v. Coates here
Awesome decision! High fives all around!
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