Summary
The Indiana Supreme Court held that the automobile exception permitted a warrantless search of an operational vehicle parked in a public place when police had probable cause to believe it contained evidence of a crime. The court concluded that the search was not justified as incident to arrest but was supported by the vehicle's mobility, public location, officers' observations, and a drug dog's alert. The court also held that the search was reasonable under Article I, section 11 of the Indiana Constitution and reversed the trial court's suppression ruling.
Topics
Practice areas
Questions Presented
- Whether the warrantless search of Hobbs's vehicle was valid under the Fourth Amendment's automobile exception when the vehicle was operational, located in a public parking lot, and officers had probable cause to believe it contained evidence of a crime.
- Whether the search was valid as a search incident to arrest.
- Whether the search was reasonable under Article I, section 11 of the Indiana Constitution.
Holdings
- The Fourth Amendment permits a warrantless search of an operational vehicle located in a public place when police have probable cause to believe the vehicle contains evidence of a crime; the automobile exception applied to Hobbs's vehicle.
- The search was not justified as a search incident to arrest because Hobbs was secured and away from the vehicle, and officers had no reasonable basis to believe the vehicle contained evidence of the unrelated crime for which he was arrested.
- The warrantless search was reasonable under Article I, section 11 of the Indiana Constitution.
- An exterior drug-dog sniff of the vehicle was not a search protected by the Fourth Amendment and required no degree of suspicion, so officers could summon the canine unit and conduct the sniff.
Key quotations
“We hold that the Fourth Amendment does not prohibit a warrantless search of an operational vehicle found in a public place if the police have probable cause to believe the vehicle contains evidence of a crime.” (1283)
“We also hold that the search was reasonable and did not violate the Indiana Constitution because the defendant was already under arrest and the dog's alert gave the officers probable cause to believe the car contained contraband.” (1283)
“For the reasons explained below, we conclude that the "automobile exception" applied here, but the "search incident to arrest" did not.” (1285)
“There therefore was no Fourth Amendment violation in the search of Hobbs's car or the seizure of the contraband found in the car.” (1287)
Factual background
On March 13, 2009, state troopers seeking to execute a Pike County felony arrest warrant observed James Hobbs leave a Pizza Hut and place an object in his automobile. Hobbs returned to the restaurant, where officers arrested him, and a drug dog later alerted to the vehicle after Hobbs refused consent to a search. Officers searched the operational vehicle in the restaurant parking lot and found marijuana, scales, sandwich bags, and rolling papers.
Procedural history
State troopers arrested Hobbs inside a Pizza Hut on an unrelated felony warrant. After a drug dog alerted to Hobbs's vehicle in the restaurant parking lot, officers searched the vehicle and found marijuana and drug paraphernalia. The trial court ruled that the warrantless search violated the Fourth Amendment and Article I, section 11 of the Indiana Constitution, suppressed the evidence, and released Hobbs on the new charges. The Court of Appeals reversed, and the Supreme Court of Indiana affirmed the reversal.