United States v. Patiutka, No. 14-4932 (4th Cir. 2015)
Annotate this CaseThe Government appealed the district court's grant of defendant's motion to suppress evidence stemming from a warrantless search of defendant's vehicle. The court concluded that the absence of probable cause to arrest defendant for any offense at the moment the trooper decided to continue the search without defendant's consent renders the search incident to arrest exception inapplicable in this case. The court also concluded that the automobile exception is inapplicable in this case because the exception requires that the police have probable cause, not just reasonable articulable suspicion. Finally, the same credibility determination by the district court that precludes application of the search incident to arrest exception also thwarts the Government’s collective-knowledge argument. Accordingly, the court affirmed the judgment.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.