State v. Williams
10 Fla. L. Weekly 100, 1985 Fla. App. LEXIS 11875, 462 So. 2d 69 (1985)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under the Fourth Amendment, probable cause to believe that a specific, identified container placed in a vehicle's trunk contains contraband does not, without more, justify a warrantless search of the entire vehicle.
Facts:
- A confidential informant told police that Williams's boyfriend was a cocaine supplier and that cocaine was kept in a safe in his apartment.
- The informant stated she had seen the open safe containing cocaine in the presence of Williams.
- Police conducted surveillance on the apartment and observed Williams and a companion exit with a “brown boxlike object” (a safe) and a paper sack.
- Williams placed both items in the trunk of her car and drove away.
- After noticing she was being followed, Williams began driving evasively.
- Police stopped Williams's vehicle, and the trunk was opened, revealing a locked safe.
- Officers then proceeded to search the interior of the vehicle, finding cocaine and marijuana in the glove compartment.
- Williams was only formally placed under arrest after the contraband was discovered in the glove compartment.
Procedural Posture:
- Williams was charged with possession of cocaine and cannabis.
- In the trial court, Williams filed a motion to suppress the evidence found in the car's trunk and glove compartment.
- The trial court denied the motion as to the evidence from the trunk but granted the motion to suppress the evidence found in the glove compartment.
- The State, as appellant, appealed the trial court's order granting the motion to suppress to the Florida First District Court of Appeal.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does probable cause to search a specific container known to be in a vehicle's trunk extend to a warrantless search of the entire vehicle, including its glove compartment?
Opinions:
Majority - Mills, Judge
No. Probable cause to believe that a specific container placed in the trunk of a vehicle contains contraband does not justify a search of the entire vehicle. The scope of a warrantless automobile search is defined by the object of the search and the place in which there is probable cause to believe that it may be found. Here, the police had probable cause specific to the container placed in the trunk; they observed it being put there, the trunk was shut, and they never lost sight of the car, meaning its contents could not have been secreted elsewhere. Therefore, the probable cause did not extend to the passenger compartment. The search was not a valid search incident to arrest because Williams was not under formal or effective arrest at the time. Finally, the inevitable discovery doctrine does not apply because the seizure of the car itself was only warranted by the fruits of the illegal search of the glove compartment.
Dissenting - Ervin, Chief Judge
Yes. The probable cause should extend to the entire vehicle. The object of the search was the cocaine, not merely the safe, and it was reasonable for experienced narcotics officers to believe that cocaine could be located in other parts of the vehicle besides the primary container. The information did not limit the location of contraband to a single container. Alternatively, the evidence is admissible under the inevitable discovery doctrine. The officers had probable cause to stop the vehicle and seize the safe from the trunk. This lawful seizure of the vehicle would have led to an inventory search, which would have inevitably uncovered the contraband in the glove compartment, regardless of the initial unlawful search.
Analysis:
This case refines the application of the automobile exception established in U.S. v. Ross by drawing a sharp distinction between generalized and container-specific probable cause. It curtails law enforcement's authority by establishing that probable cause to search a specific container does not automatically ripen into probable cause to search the entire vehicle. This decision reinforces the principle that the scope of a warrantless search must be strictly tied to and justified by the scope of the probable cause that underpins it, preventing officers from using narrow probable cause as a pretext for a broader, exploratory search.
