State v. Andera
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The Supreme Court affirmed Defendant's drug possession conviction, holding that the district court did not err in overruling Defendant's motion to suppress.
Defendant was a passenger in a vehicle that was stopped for not having license plates. During the traffic stop, the officer obtained the driver's consent to search the vehicle. The officers found methamphetamine in a purse located on the front passenger floorboard. The purse belonged to Defendant. Defendant filed a motion to suppress, arguing that the search violated her Fourth Amendment protections against unlawful searches and seizures because she did not consent to the search of her purse. The district court overruled the motion. After a bench trial, Defendant was found guilty. The Supreme Court affirmed, holding that the search was constitutional because the officer reasonably believed that the driver could have owned the purse and the officer found the contraband in plain view upon opening the wallet that contained Defendant's identification.
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