United States v. Fields, 456 F.3d 519 (5th Cir. 2006). · Go Syfert
United States v. Fields, 456 F.3d 519 (5th Cir. 2006). Cases Citing This Book View Copy Cite
66 citation events (66 in the last 25 years) across 17 distinct courts.
Strongest positive: State v. Julius (ncctapp, 2026-02-04) · Strongest negative: Robinson v. Cook (ca1, 2013-01-23)
Treatment trajectory · 2007 → 2026 · click a year to view as-of
2007 2016 2026
Top citers, strongest first. 44 distinct citers. How cited ↗
cited Cited "but see" Robinson v. Cook
1st Cir. · 2013 · signal: but see · confidence high
But see United States v. Fields, 456 F.3d 519, 524-25 (5th Cir.2006). 5 .
discussed Cited as authority (rule) State v. Julius
N.C. Ct. App. · 2026 · confidence medium
See also United States v. Mercado, 307 F.3d 1226 , 1228–29 (10th Cir. 2002) (finding that “mere temporary immobility due to a readily repairable problem . . . does not remove the vehicle from the category of ‘readily mobile’ ”); Unites States v. Fields, 456 F.3d 519, 524 (5th Cir. 2006) (exception applies to crashed vehicle with repairable issues).
discussed Cited as authority (rule) Carson v. Cain
S.D. Miss. · 2025 · confidence medium
Under the automobile exception, police are allowed “to search a vehicle if they have probable cause to believe that the vehicle contains contraband.” United States v. Ortiz, 781 F.3d 221, 229 (5th Cir. 2015) (quoting United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006)).
discussed Cited as authority (rule) United States v. Riojas
5th Cir. · 2025 · confidence medium
United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006); see, e.g., United States v. McSween, 53 F.3d 684, 686 (5th Cir. 1995) (concluding there was probable cause to search a car based in part on the officer’s experience and training in detection of marijuana by its odor).
discussed Cited as authority (rule) State of Missouri v. Douglas Beeson
Mo. Ct. App. · 2025 · confidence medium
There are two rationales for the automobile exception: first, exigent circumstances from the inherent mobility of automobiles, see id., and second, a reduced expectation of privacy in an automobile due to “pervasive regulation by official authorities.” State v. Donohoe, 770 S.W.2d 252, 255 (Mo. App. W.D. 1989); see also United States v. Vittetoe, 86 F.4th 1200, 1203 (8th Cir. 2023); United States v. Fields, 456 F.3d 519, 524 (5th Cir. 2006).
discussed Cited as authority (rule) United States v. Hemphill
5th Cir. · 2024 · confidence medium
Id. (citing United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006)). 20 Case: 23-50675 Document: 82-1 Page: 21 Date Filed: 12/20/2024 No. 23-50675 Here, the law enforcement officers had more than sufficient probable cause to support a search of Hemphill’s vehicle.
discussed Cited as authority (rule) United States v. Simpson (2×) also: Cited "see"
5th Cir. · 2024 · confidence medium
United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
cited Cited as authority (rule) Joyce v. Young County Sheriff's Office
N.D. Tex. · 2024 · confidence medium
United States v. Ortiz, 781 F.3d 221, 229 (5th Cir. 2015); United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited as authority (rule) Brown v. Baton Rouge Police Department
M.D. La. · 2024 · confidence medium
La. 2016)(quoting United States v. Ortiz, 781 F.3d 221, 229 (5th Cir. 2015) (quoting United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006))). 93 Id. at 906 (citing Alabama v. White, 496 U.S. 325, 330 (1990)). 94 See id.; United States v. Jones, 187 F.Supp.3d 714 (M.D.
discussed Cited as authority (rule) Lee v. Lawerence
M.D. La. · 2024 · confidence medium
La. 2016)(quoting United States v. Ortiz, 781 F.3d 221, 229 (5th Cir. 2015) (quoting United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006))). 93 Id. at 906 (citing Alabama v. White, 496 U.S. 325, 330 (1990)). 94 See id.; United States v. Jones, 187 F.Supp.3d 714 (M.D.
cited Cited as authority (rule) United States v. Clayton
5th Cir. · 2024 · confidence medium
See Rountree v. Lopinto, 976 F.3d 606, 609 (5th Cir. 2020); United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006); California v. Acevedo, 500 U.S. 565, 580 (1991).
cited Cited as authority (rule) United States v. Clayton
5th Cir. · 2024 · confidence medium
See Rountree v. Lopinto, 976 F.3d 606, 609 (5th Cir. 2020); United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006); California v. Acevedo, 500 U.S. 565, 580 (1991).
discussed Cited as authority (rule) United States v. Goldsmith
5th Cir. · 2024 · confidence medium
If law enforcement officials have probable cause to believe that a vehicle contains contraband, a warrantless search is permitted under the “automobile exception.” United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
cited Cited as authority (rule) United States v. Phillips
5th Cir. · 2024 · confidence medium
United States v. Ortiz, 781 F.3d 221, 229 (5th Cir. 2015) (quoting United States v. Fields, 456 F.3d 519, 523 (5th Cir.2006)).
discussed Cited as authority (rule) Commonwealth of Virginia v. Leigh Ann Jennings
Va. Ct. App. · 2024 · confidence medium
See, e.g., Farris v. State, No. 12-22-00235-CR, 2023 Tex. App. LEXIS 7055 , at *9-11 (Tex. App. Sep. 6, 2023) (holding that automobile exception applied despite that the car had two flat tires and had been involved in an accident); Vassar v. State, 99 P.3d 987 (Wyo. 2004) (rejecting defendant’s argument that “because he was hospitalized and his vehicle was damaged and allegedly immobile, the exigencies underlying the automobile exception did not exist”); People v. Carter, 655 N.W.2d 236 (Mich. Ct. App. 2002) (holding that automobile exception did not rise or fall depending on the peculia…
discussed Cited as authority (rule) United States v. Sanders
5th Cir. · 2023 · confidence medium
If law enforcement officials have probable cause to believe that a vehicle contains contraband, a warrantless search is permitted under the “automobile exception.” United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited as authority (rule) James Ralph Farris, Jr. v. the State of Texas
Tex. App. · 2023 · confidence medium
See United States v. Short, 2 F.4th 1076, 1079-80 (8th Cir. 2021) (“an easily repairable flat tire did not cause the vehicle to lose its inherent mobility”), cert. denied, 142 S. Ct. 626 (2021); United States v. Fields, 456 F.3d 519, 524 (5th Cir. 2006) (“Even where an automobile is not immediately mobile at the time of the search, ‘the lesser expectation of privacy resulting from its use as a readily mobile vehicle justifie[s] application of the vehicular exception.’” (quoting California v. Carney, 471 U.S. 386, 391 , 105 S. Ct. 2066 , 85 L.
cited Cited as authority (rule) Ellis v. Garza-Lopez
5th Cir. · 2023 · confidence medium
See Carroll v. Ellington, 800 F.3d 154 , 170–71 (5th Cir. 2015); United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
cited Cited as authority (rule) United States v. Johnson
5th Cir. · 2023 · confidence medium
United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
cited Cited as authority (rule) Martinez v. Wallace
W.D. Tex. · 2021 · confidence medium
United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited as authority (rule) James Rountree v. Joseph Lopinto, III
5th Cir. · 2020 · confidence medium
Justified “by the mobility of vehicles and occupants’ reduced expectations of privacy while traveling on public roads,” United States v. Beene, 818 F.3d 157, 164 (5th Cir. 2016), the exception permits the “police to search a vehicle if they have probable cause to believe that the vehicle contains contraband,” United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited as authority (rule) United States v. Justin Ortiz (2×)
5th Cir. · 2015 · confidence medium
The most relevant exception to the warrant requirement is the automobile exception, which “allows police to search a vehicle if they have probable cause to believe that the vehicle con- tains contraband.” United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited as authority (rule) United States v. Mooty
E.D. Pa. · 2015 · signal: cf. · confidence medium
Cf., e.g., United States v. Fields, 456 F.3d 519, 523 (5th Cir.2006) (applying automobile exception after automobile had crashed into a wall); Mercado, 307 F.3d at 1229 (vehicle immobile in a repair shop).
discussed Cited as authority (rule) United States v. Albert Guzman
5th Cir. · 2014 · confidence medium
In addition, where a residence was used to sell drugs rather than “regularly use[d] . . . for residential purposes,” we have held that “the Fourth Amendment concerns that arise when the police search a car that is parked in a driveway of a home, without a warrant, are not present.” United States v. Fields, 456 F.3d 519, 525 (5th Cir. 2006); see also 3 W.
discussed Cited as authority (rule) United States v. Albert Guzman
5th Cir. · 2014 · confidence medium
In addition, where a residence was used to sell drugs rather than "regularly use[d] ... for residential purposes,” we have held that "the Fourth Amendment concerns that arise when the police search a car that is parked in a driveway of a home, without a warrant, are not present.” United States v. Fields, 456 F.3d 519, 525 (5th Cir.2006); see also 3 W.
discussed Cited as authority (rule) United States v. Albert Guzman
5th Cir. · 2014 · confidence medium
In addition, where a residence was used to sell drugs rather than “regularly use[d] . . . for residential purposes,” we have held that “the Fourth Amendment concerns that arise when the police search a car that is parked in a driveway of a home, without a warrant, are not present.” United States v. Fields, 456 F.3d 519, 525 (5th Cir. 2006); see also 3 W.
cited Cited as authority (rule) United States v. Vincent Tovar, Jr.
5th Cir. · 2012 · confidence medium
See Illinois v. Gates, 462 U.S. 213, 241 , 103 S.Ct. 2317 , 76 L.Ed.2d 527 (1983); United States v. Fields, 456 F.3d 519, 523 (5th Cir.2006).
discussed Cited as authority (rule) United States v. Goncalves
1st Cir. · 2011 · confidence medium
Finally, a number of circuits have upheld driveway searches with probable cause but no warrant: three have squarely applied the automobile exception to permit searches of vehicles parked in the driveway of the defendant’s own residence, 3 while others including this one have permitted such searches of vehicles in private driveways that were not the defendant’s residence. 4 A few others have expressed doubts in light of Coolidge, e.g., United States v. Fields, 456 F.3d 519, 524-25 (5th Cir.), cert. denied, 549 U.S. 1046 , 127 S.Ct. 614 , 166 L.Ed.2d 455 (2006), but no circuit appears to rea…
discussed Cited as authority (rule) United States v. Richard Ballard (2×) also: Cited "see"
5th Cir. · 2010 · confidence medium
“Probable cause to search an automobile exists where trustworthy facts and circumstances within the officer’s personal knowledge would cause a reasonably prudent man to believe that the vehicle contains contraband.” United States v. Castelo, 415 F.3d 407, 412 (5th Cir.2005) (internal quotation marks and citation omitted). *360 “Probable cause is determined by examining the totality of the circumstances.” United States v. Fields, 456 F.3d 519, 523 (5th Cir.2006).
discussed Cited as authority (rule) United States v. DeJear
10th Cir. · 2009 · confidence medium
We acknowledge that some courts have concluded that “the automobile exception [to the warrant requirement] may not apply when it is parked at the residence of the criminal defendant challenging the constitutionality of the search.” United States v. Fields, 456 F.3d 519, 524-25 (5th Cir.2006).
cited Cited as authority (rule) United States v. Grazioso
5th Cir. · 2008 · confidence medium
United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited as authority (rule) United States v. Smith
D. Mass. · 2008 · confidence medium
See, e.g., United States v. Hines, 449 F.3d 808 (7th Cir.2006); United States v. Brookins, 345 F.3d 231 (4th Cir.2003); United States v. Fladten, 230 F.3d 1083 (8th Cir.2000); United States v. Markham, 844 F.2d 366, 368 (6th Cir.1988); United States v. Hamilton, 792 F.2d 837, 843 (9th Cir.1986). 2 The Fourth Circuit has suggested, however, that “heightened privacy interests may be triggered when a vehicle is encountered on private property”, Brookins, 345 F.3d at 237 n. 8, and the Fifth Circuit has stated that the motor vehicle exception “may not apply when a vehicle is parked at the res…
discussed Cited as authority (rule) United States v. Delaurier
5th Cir. · 2007 · confidence medium
Additional facts in the record make clear that the subsequent search of De-Laurier’s vehicle was justified by the automobile exception, which allows police to search a vehicle if they have probable cause to believe that the vehicle contains contraband, provided that the car is “readily mobile” and “found stationary in a place not regularly used for residential purposes.” United States v. Fields, 456 F.3d 519, 523-24 (5th Cir.2006) (citations and internal quotation omitted).
discussed Cited "see" United States v. Leon (2×)
5th Cir. · 2021 · signal: see · confidence high
“Under the automobile exception, police may stop and search a vehicle without obtaining a warrant if they have probable cause to believe it contains contraband.” United States v. Beene, 818 F.3d 157, 164 (5th Cir. 2016); see United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited "see" United States v. Garza (2×)
5th Cir. · 2021 · signal: see · confidence high
See United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
cited Cited "see" United States v. Jonathan Beasley
5th Cir. · 2020 · signal: see · confidence high
See United States v. Fields, 456 F.3d 519, 523-24 (5th Cir. 2006); United States v. McSween, 53 F.3d 684, 686 (5th Cir. 1995).
cited Cited "see" United States v. Rickey Beene
5th Cir. · 2018 · signal: see · confidence high
See United States v. Fields, 456 F.3d 519, 523 (5th Cir. 2006).
discussed Cited "see" United States v. Beene (2×)
W.D. La. · 2016 · signal: see · confidence high
See United States v. Fields, 456 F.3d 519, 525 (5th Cir. 2006); United States v. Sinisterra, 77 F.3d 101 (5th Cir. 1996).
discussed Cited "see" United States v. Rickey Beene (2×)
5th Cir. · 2016 · signal: see · confidence high
See generally United States v. Fields, 456 F.3d 519, 523 (5th Cir.2006).
discussed Cited "see" United States v. Earnest Ross
5th Cir. · 2010 · signal: see · confidence high
See generally, United States v. Fields, 456 F.3d 519, 523 (5th Cir.2006) ("The automobile exception allows police to search a vehicle if they have probable cause to believe that the vehicle contains contraband.").
discussed Cited "see" United States v. Blaylock (2×)
8th Cir. · 2008 · signal: see · confidence high
See United States v. Fields, 456 F.3d 519, 524-25 (5th Cir.2006) (noting that the automobile exception "may not apply when a vehicle is parked at the residence of the criminal defendant challenging the constitutionality of the search"); United States v. Brookins, 345 F.3d 231 , 237 n. 8 (4th Cir.2003) (suggesting that "heightened privacy interests may be triggered when a vehicle is encountered on private property"); but see United States v. Hines, 449 F.3d 808, 810, 815 (7th Cir.2006) (applying the automobile exception to a car parked on a private driveway); United States v. Markham, 844 F.2d …
discussed Cited "see" United States v. Robert Blaylock
8th Cir. · 2008 · signal: see · confidence high
See United States v. Fields, 456 F.3d 519, 524-25 (5th Cir. 2006) (noting that the automobile exception “may not apply when a vehicle is parked at the residence of the criminal defendant challenging the constitutionality of the search”); United States v. Brookins, 345 F.3d 231 , 237 n.8 (4th Cir. 2003) (suggesting that “heightened privacy interests may be triggered when a vehicle is encountered on private property”); but see United States v. Hines, 449 F.3d 808, 810, 815 (7th Cir. 2006) (applying the automobile exception to a car parked on a private driveway); United States v. Markham,…
discussed Cited "see, e.g." United States v. Grayson Eagan
11th Cir. · 2025 · signal: see also · confidence low
Although he argues that the car was not operational because he crashed it, “[e]ven in cases where an automobile was not immediately mobile, the lesser expectation of privacy resulting from its use as a readily mobile vehicle justifie[s] application of the vehicular exception.” California v. Carney, 471 U.S. 386, 391 (1985); see also United States v. Fields, 456 F.3d 519 , 523–24 (5th Cir. 2006) (applying the automobile exception where the defendant crashed his car following a police chase).
discussed Cited "see, e.g." Com. v. Mamdouh, A.
Pa. Super. Ct. · 2015 · signal: see, e.g. · confidence medium
See e.g., United States v. Fields, 456 F.3d 519, 525 (5th Cir. 2006) (distinguishing Coolidge by noting, “The Fourth Amendment concerns that arise when the police search a car that is parked in the driveway of a home, without a warrant, are not present here.”).
Retrieving the full opinion text from the archive…
UNITED STATES of America, Plaintiff-Appellee,
v.
Anthony FIELDS, Defendant-Appellant
05-10486.
Court of Appeals for the Fifth Circuit.
Jul 18, 2006.
456 F.3d 519
2006 U.S. App. LEXIS 18039
2006 WL 1991567
John E. Kull (argued), Dallas, TX, for U.S., Christopher Allen Curtis (argued), Fort Worth, TX, for Fields.
Demoss, Benavides, Prado.
Cited by 47 opinions  |  Published
Pinpoint authority: bottom 56%
PRADO, Circuit Judge:

A jury found Defendant-Appellant Anthony Fields guilty of drug related charges and of being a felon in possession of a firearm. At trial, Fields moved to suppress evidence found in his vehicle, which the police searched on three separate occasions around the time of his arrest. The district court denied Fields’ motion to suppress the evidence, reasoning that the challenged search of Fields’ vehicle was a valid search incident to an arrest. We conclude that the warrantless search of Fields’ vehicle was valid under the automobile exception to the warrant requirement, and AFFIRM the district court’s denial of Fields’ motion to suppress.

I. Facts

Michael Neff, a narcotics officer, received information from a confidential source that an individual named “T-Bone” was selling illegal narcotics out of a duplex[*521] in Ft. Worth. After further investigation, Neff determined that T-Bone was Anthony Fields, who owned a black Impala. On August 24, 2004, Neff went to an address in Arlington, Texas, which he believed to be Fields’ residence. Neff watched Fields leave the residence and drive away in his Impala. He tried to follow Fields, but he was unsuccessful. Another narcotics officer, Kevin Turner, located Fields and followed him to a duplex. This was the same duplex described by the confidential source.

Narcotics officers maintained visual surveillance of the duplex and Impala, which was parked in the driveway of the duplex. During 45 minutes to one hour of surveillance of Fields, narcotics officer Jerry Brown saw eight to ten cars arrive at the duplex at different times. The car’s occupants would talk to Fields briefly. After that, Fields would go into the duplex and return to the occupants of the cars. Fields would shake their hands and then the occupants of the ears would leave. Brown concluded that Fields was engaging in narcotics transactions.

After the last car left, Brown observed Fields make three trips to the Impala. On the first trip, Fields carried a black bag. On the second trip, Fields had an electronic device. On the third trip, Fields put a small cooler in the Impala. Fields then drove away in the Impala.

Neff and Brown decided they should pull Fields over. Brown radioed Chuck Wiesman, an officer who was in a marked police car. Brown instructed Wiesman to follow Fields and to pull him over if he committed a traffic violation. Wiesman saw Fields run a stop sign, so he turned on his overhead lights to pull Fields over. Instead of stopping, Fields accelerated. Fields began driving at high speed, drove across two vacant lots, lost control of his car, and ran the Impala into the side of the same duplex that he had just left.

Fields exited the Impala through the driver’s side window and ran on foot. Wiesman pursued Fields initially, but stopped after Fields jumped over a fence. Wiesman then went back to the Impala and opened the passenger door to see if anyone else was in the car (“first search”). No one was inside, so Wiesman shut the door. A few minutes after the first search, Wiesman heard over the radio that Fields had been taken into custody. He went back to the Impala and again opened the passenger door (“second search”). Wies-man saw a black bag in the passenger door pocket. The bag was open and contained narcotics.

Meanwhile, Officer Brown chased and arrested Fields. The Government contends that Fields was arrested one and a half blocks away from the Impala. Fields contends he was arrested three to four blocks from the Impala. Officers handcuffed Fields, placed him in the back of a patrol car, and returned him to the Impala. Fields remained in the squad car about 30 feet away from the Impala while crime scene officers photographed and searched the car (“third search”). In addition to the black bag with narcotics, the crime scene officers found narcotics in the cooler and a handgun in the front passenger seat.

Officer Neff obtained a search warrant to search the duplex. It did not appear that anyone lived there. The duplex contained minimal furniture. One bedroom was filled with yard equipment and trash. The bathroom had no toiletries or towels. There were a few articles of clothing in the duplex. The windows were covered with foil or black plastic. There were twenty-two boxes of sandwich bags inside the duplex.

[*522] II. Procedural History-

Fields was charged in a three count indictment with three drug related charges. On December 15, 2004, a su-perceding indictment added a fourth count, charging Fields with being a felon in possession of a firearm, and on December 20, 2004, the Government filed a sentencing enhancement information.

The case proceeded to trial. At a bench conference after jury selection and prior to presenting the indictment to the jury, Fields made an oral motion to suppress evidence because he contended that the second search of the Impala, conducted without a warrant, violated the Fourth Amendment. After a presentation of the case law outside the presence of the jury, the district court denied the motion to suppress, stating:

The opening of the door was a perfectly legitimate thing to do to see if there was anybody else in the vehicle, to see if there was anything that could pose an immediate threat to the safety of the officers. Even the search of the vehicle after they brought the man back was consistent with the Thornton case because of his proximity to the vehicle that was being searched. Plus, once the drugs fell out of the vehicle, there was a basis, a constitutional basis, for searching the vehicle at that time because it was apparent that contraband was in the vehicle.

A jury found Fields guilty on all four counts alleged in the superceding indictment. Fields was sentenced to a total aggregate sentence of 300 months imprisonment, a ten year term of supervised release, and a $100.00 mandatory special assessment. Fields timely filed his notice of appeal on April 7, 2005.

III. Discussion

Fields argues that the second search of his vehicle by officer Wiesman was an unreasonable warrantless search in violation of the Fourth Amendment. He contends that, as a result, the evidence seized from his vehicle should be suppressed. “This court reviews the district court’s fact-findings on a motion to suppress for clear error and reviews de novo the ‘ultimate determination of Fourth Amendment reasonableness.’ ” United States v. Sinisterra, 77 F.3d 101, 104 (5th Cir.1996) (citing United States v. Seals, 987 F.2d 1102, 1106 (5th Cir.1993)).

The district court concluded that the warrantless search of Fields’ vehicle did not violate the Fourth Amendment because it was a valid search incident to an arrest. The search incident to an arrest exception to the warrant requirement “allows police to search the passenger compartment of a vehicle incident to a lawful custodial arrest of both ‘occupants’ and ‘recent occupants’ ” of the vehicle. Thornton v. United States, 541 U.S. 615, 622, 124 S.Ct. 2127, 158 L.Ed.2d 905 (2004)(citing New York v. Belton, 453 U.S. 454, 460, 101 S.Ct. 2860, 69 L.Ed.2d 768 (1981)). An arrestee’s status as a recent occupant turns on “his temporal or spatial relationship to the car at the time of the arrest and search.” Id. However, the Thornton Court “never specified the physical distance between the defendant and his car at the time he was arrested” [1] that would constitute a “recent occupant.” [2] At first[*523] blush it seems that Fields did not have a close spatial relationship to his vehicle at the time of the arrest and search because he was anywhere from one and a half to four blocks away from his vehicle when he was arrested and during the contemporaneous search. See United States v. Pittman, 411 F.3d 813, 815-17 (7th Cir.2005)(questioning whether an arrest a half a block away from the vehicle searched is too great a distance to constitute a search incident to an arrest under Thornton, but upholding the validity of the search under the automobile exception). [3] However, we need not decide this issue because the search was valid under the automobile exception to the warrant requirement. [4]

The automobile exception allows police to search a vehicle if they have probable cause to believe that the vehicle contains contraband. Maryland v. Dyson, 527 U.S. 465, 467, 119 S.Ct. 2013, 144 L.Ed.2d 442 (1999). There was probable cause to believe that Fields’ vehicle contained contraband at the time of the search at issue. Probable cause is determined by examining the totality of the circumstances. Illinois v. Gates, 462 U.S. 213, 230-31, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983). A narcotics officer received information from a confidential source that Fields was selling illegal narcotics. [5] Officers observed Fields in his black Impala and followed Fields when he drove to a duplex. The officers maintained visual surveillance of Fields for nearly an hour. During the surveillance, the officers observed activity that they, through their training and experience, associated with drug transactions. Following the observed transactions, officers watched Fields place a black bag, an electronic device and a cooler inside his Impala. The officers watched Fields get into his car and drive away. When the police followed Fields, he evaded them. Instead of pulling over when Officer Wiesman turned on his lights, Fields accelerated, drove at a very high speed, lost control of his car and[*524] crashed the Impala into the side of the duplex. After the crash, Fields climbed out the driver’s side window of the car and ran on foot and was eventually arrested. All of these events occurred before Officer Wiesman conducted the second search of Fields’ vehicle. The events prior to the search, taken together, amount to probable cause. See, e.g., id. at 241, 103 S.Ct. 2317 (“Our decisions applying the totality-of-the-circumstances analysis outlined above have consistently recognized the value of corroboration of details of an informant’s tip by independent police work.”); United States v. Vega, 221 F.3d 789, 799 n. 26 (5th Cir.2000) (“[Unprovoked flight] is among the relevant contextual considerations in the probable cause analysis.”); see also Illinois v. Wardlow, 528 U.S. 119, 124, 120 S.Ct. 673, 145 L.Ed.2d 570 (2000) (“Headlong flight-wherever it occurs-is the consummate act of evasion: It is not necessarily indicative of wrongdoing, but it is certainly suggestive of such.”).

First, Fields argues that the automobile exception cannot apply because it requires that the vehicle searched be “readily mobile,” and that due to the crash, Fields’ Impala was not readily mobile when the officer searched it. However, Fields mischaracterizes the automobile exception. Even where an automobile is not immediately mobile at the time of the search, “the lesser expectation of privacy resulting from its use as a readily mobile vehicle justified] application of the vehicular exception.” California v. Carney, 471 U.S. 386, 391, 105 S.Ct. 2066, 85 L.Ed.2d 406 (1985)(emphasis added). Fields used his Impala as a readily mobile vehicle throughout the police chase and in all the events leading up to his arrest and the search in question.

Furthermore, the fact that Fields crashed his car after a police chase does not increase his privacy interest in his vehicle. “An essential element to a successful challenge of a search or seizure on Fourth Amendment grounds is the existence of a legitimate expectation of privacy.” United States v. Salvucci, 448 U.S. 83, 92-93, 100 S.Ct. 2547, 65 L.Ed.2d 619 (1980). “[R]educed expectations of privacy [in a vehicle] derive ... from the pervasive regulation of vehicles capable of traveling on the public highways.” Carney, 471 U.S. at 392, 105 S.Ct. 2066. [6] Fields disregarded these “pervasive regulations”: the Impala was involved in a high speed police chase immediately prior to the search; Fields ran a stop sign, drove erratically, and crashed into the side wall of a building. If the car was not mobile at the time of the search, [7] it was solely by virtue of Fields complete disregard of driving regulations, and this does not entitle him to a heightened privacy interest.

Second, Fields contends that the automobile exception does not apply because his vehicle was located on private property, the duplex, at the time of the search. California v. Carney clarifies that the automobile exception applies when the vehicle searched is “found stationary in a place not regularly used for residential purposes.” 471 U.S. 386, 392, 105 S.Ct. 2066, 85 L.Ed.2d 406 (1985). Thus, we have concluded that automobile exception[*525] may not apply when a vehicle is parked at the residence of the criminal defendant challenging the constitutionality of the search. See United States v. Sinisterra, 77 F.3d 101, 104-05 (5th Cir.1996) (“Here, the mall parking lot was not related to anyone’s residence.”); see also United States v. Williams, 124 Fed.Appx. 885, 887 (5th Cir.2005) (“[S]ome support exists for the proposition that the automobile exception does not apply when a vehicle is parked in the defendant’s private driveway ....”).

As an initial matter, the automobile exception applies because Fields did not regularly use the duplex for residential purposes. While there is some indication in the record that Fields had an ownership interest in the duplex, a search of the duplex revealed that Fields did not use the duplex as a residence; he used it to sell his drags. Furthermore, Fields’ vehicle was not parked in the driveway. Rather, Fields had crashed the car into the side of the building. The Fourth Amendment concerns that arise when the police search a car that is parked in the driveway of a home, without a warrant, are not present here. See Coolidge v. New Hampshire, 403 U.S. 443, 461-62, 91 S.Ct. 2022, 29 L.Ed.2d 564 (1971); see also United States v. Orona, 166 Fed.Appx. 765, 766 (5th Cir.2006) (“[E]xigent circumstances are [ ] required to justify a warrantless search of a vehicle when the vehicle is parked in the driveway of a residence.”).

The search of Fields’ vehicle was valid under the automobile exception to the warrant requirement, and we AFFIRM the district court’s denial of Fields’ motion to suppress.

1

. United States v. Jones, 155 Fed.Appx. 204, 207 (6th Cir.2005) (holding that an arrest ten to fifteen feet from the car is a close spatial relationship).

2

. The Thornton Court declined to address whether a "recent occupant” of a vehicle needed to be within reaching distance of the car to constitute a close spatial relationship.[*523] Thornton, 541 U.S. at 622 n. 2, 124 S.Ct. 2127.

3

. Pittman also raises doubts as to the Seventh Circuit’s holding in United States v. Arango, 879 F.2d 1501 (7th Cir.1989). In that case, the court upheld the validity of a search of the defendant's vehicle when he was a mile away at the time of the arrest. Notably, Arango precedes Thornton.

4

. Fields contends that the government cannot raise the automobile exception for the first time on appeal. The government did not raise the automobile exception in the district court because that court found that the search in question was a valid search incident to an arrest. The issue underlying both the automobile exception and the search incident to an arrest exception to the warrant requirement is the ultimate reasonableness of a war-rantless search. See Carroll v. United States, 267 U.S. 132, 153, 45 S.Ct. 280, 69 L.Ed. 543 (1925) (explaining that the Fourth Amendment guarantees freedom from unreasonable searches and seizures); see also United States v. Ross, 456 U.S. 798, 809, 102 S.Ct. 2157, 72 L.Ed.2d 572 (1982) ("[An automobile] search is not unreasonable if based on facts that would justify the issuance of a warrant, even though a warrant has not actually been obtained.”); United States v. Robinson, 414 U.S. 218, 235, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973) (stating that a search‘incident to an arrest is a reasonable intrusion under the Fourth Amendment). At trial, the Government opposed Fields’ motion to suppress and argued that the search of Fields’ vehicle was reasonable. We review a search for Fourth Amendment reasonableness, and that issue has been preserved for appeal. Sinisterra, 77 F.3d at 104. The Government was not required to "raise innumerable issues despite an apparent lack of necessity to do so.” United States v. Cardona, 955 F.2d 976, 982 (5th Cir.1992).

5

.The confidential source informed the narcotics officer that someone named "T-Bone” was selling illegal narcotics. The investigating officers knew Fields as T-Bone.

6

. In California v. Carney, the Supreme Court explained that “although ready mobility alone was perhaps the original justification for the vehicle exception, [its] later cases have made clear that ready mobility is not the only basis for the exception ... the expectation of privacy with respect to one's automobile is significantly less than that relating to one's home or office.” Carney, 471 U.S. at 391, 105 S.Ct. 2066 (internal quotations omitted).

7

. There is no evidence in the record to indicate whether the Impala was drivable after the crash.