United States v. Edwards, No. 13-3397 (7th Cir. 2014)
Annotate this CaseEdwards was pulled over on suspicion of driving a stolen vehicle and the police found a sawed-off shotgun in the car. Moments before the stop, his girlfriend had called 911 to report that Edwards had just stolen her car. A nearby officer heard dispatch, spotted the car, and initiated a traffic stop. Edwards was driving, did not have a valid driver’s license, could not produce the vehicle’s registration, and was evasive about whether he had his girlfriend’s permission to drive the car, so the officer placed him under arrest. A search of the car revealed the sawed-off shotgun on the floor behind the front passenger seat. Edwards admitted the gun was his. Edwards was charged with possession of a firearm as a felon and possession of an unregistered short-barreled shotgun. The district court granted a motion to suppress the gun. The Seventh Circuit reversed. A warrantless search of a vehicle incident to the arrest of one of its occupants requires reason to believe that the vehicle contains evidence of the offense of arrest. Edwards was arrested for driving a vehicle without the owner’s consent; it was entirely reasonable to believe that evidence of the car’s ownership—its registration or title—would be found in the car. The search was valid
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