Hodges v. StateAnnotate this Case
The Supreme Court affirmed the decision of the trial court ordering state police officers to turn over to federal authorities a shipped box containing U.S. currency wrapped in multiple layers of sealed packaging that bore the odor of narcotics, holding that the totality of the circumstances established the requisite probable cause to believe the money was proceeds of drug trafficking.
The shipped box in this case displayed hallmarks of parcels containing drugs and drug money. The officer sought and was granted a warrant authorizing a search of the package and seizure of proceeds of drug trafficking. Officers proceeded to open the box, and a canine alerted that the money contained therein, and not just the packaging surrounding it, contained the odor of narcotics. The officers then seized the cash and obtained a court order to turn it over to federal authorities. Appellant, the individual who shipped the parcel, argued on appeal that the seizure exceeded the scope of the warrant. The Supreme Court affirmed, holding (1) all the circumstances supplied a basis for probable cause to believe the cash was proceeds of drug trafficking; and (2) therefore, the seizure was lawful, and the trial court properly made its order transferring the property to the federal government.