Washington v. Snapp
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Defendant Daniel Snapp was stopped by police when an officer observed air fresheners hanging from Defendant's rear view mirror that blocked the driver's view. Upon further inspection, the officer observed a carabiner that "patched together" the driver's seat belt, which he believed to be insufficient and defective. As the officer pulled Defendant's car over, he testified he saw Defendant dip his right shoulder as if he was placing something under the seat. The officer would ultimately arrest Defendant for driving under the influence, and a search of the car was conducted incident to his arrest. The officer found that Defendant had multiple credit and identification cards with other peoples' identities. The State would charge Defendant with 22 counts of identity theft and for possession of drug paraphernalia. Defendant moved to suppress the evidence obtained from that search, arguing the initial stop was unlawful. Acting pro se, Defendant petitioned the Supreme Court for discretionary review, arguing that the search violated the Washington Constitution. Finding that the warrantless searches of Defendant's vehicle violated his right to privacy, the Supreme Court reversed Defendant's conviction and remanded the case for further proceedings.
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