Colorado v. Coates
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The State brought an interlocutory appeal to challenge a district court's suppression of evidence seized from the trunk of the Defendant Brittney Coates' vehicle. Upon discovering a bindle and single prescription pill in the driver's pants pocket, the police arrested the driver, placed him in their patrol car, and searched the vehicle. The district court found that the police lacked any reasonable and articulable basis to search Defendant's trunk incident to the arrest of the driver in accordance with "Arizona v. Gant," (556 U.S. 332 (2009)), and that they also lacked probable cause for a warrantless search of the vehicle's trunk pursuant to the automobile exception. The Supreme Court affirmed. It held, however, that because the evidence for which suppression was sought was not seized from the passenger compartment of Defendant's vehicle, the search-incident-to-arrest exception could not justify its seizure under any circumstances. Instead, the Supreme Court affirmed on the grounds that it was able to determine from the district court's findings of fact that the police lacked probable cause to search Defendant's vehicle, whether or not they would have been justified in searching the passenger compartment on less than probable cause.
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