South Carolina v. Brown
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Defendant Danny Cortez Brown was convicted of trafficking in cocaine and sentenced to twenty-five years in prison. He appealed, arguing the trial court erred in denying his motion to suppress the cocaine, which was seized from a duffel bag after his arrest for an open container violation during an automobile stop. The Court of Appeals reversed on the basis the search was improper under "Arizona v. Gant," (556 U.S. 332 (2009)). Upon review, the Supreme Court concluded that the Court of Appeals properly applied "Gant" and found the warrantless police search conducted incident to Defendant's arrest for an open container violation was illegal. Furthermore, the Court held that pursuant to the United States Supreme Court's subsequent pronouncement in "United States v. Davis," (131 S. Ct. 2419 (2011)) that the exclusionary rule was not applicable to this case because the officer relied upon existing appellate precedent at the time he conducted his search. Consequently, the decision of the Court of Appeals was reversed.
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