California v. LeeAnnotate this Case
Following a traffic stop, officers searched Brandon Lee's car without a warrant and discovered 56 grams of cocaine, a firearm, and other items associated with selling narcotics. After Lee was charged with various drug and weapons offenses, he filed a motion to suppress the evidence obtained from the warrantless vehicle search. The trial court granted Lee's motion, rejecting the State's contentions that the search was proper under the automobile exception as supported by probable cause or, alternatively, as an inventory search of a vehicle following an impound. The Court of Appeal determined the trial court properly concluded that Lee's possession of a small amount of marijuana was of little relevance in assessing probable cause. Because the other factors relied on by the State were also of minimal significance, the Court concluded that even considering the totality of circumstances known to the officer, there did not exist " ' "a fair probability that contraband or evidence of a crime will be found." ' " The Court likewise found no error in the trial court's conclusion that the search was not valid as an inventory search. The Court therefore affirmed the order granting Lee's motion to suppress the evidence obtained from the unlawful search of his car.