automobile exception (Washington) · Go Syfert
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automobile exception in Washington

14 Washington opinions name it 2 courts 1934–2016 0 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
State v. Portergreen
washctapp · 2000 · cited in 2 Washington opinions naming this issue, 2002–2003
2 sentences

2003See e.g., State v. Porter, 102 Wash.App. 327, 333-34 , 6 P.3d 1245 (2000) (search of vehicle unlawful when suspect arrested 300 feet from vehicle while walking his dog and directed to return to his vehicle).

2002See, e.g., State v. Porter, 102 Wn.

22
Chambers v. Maroneygreen
scotus · 1970 · cited in 3 Washington opinions naming this issue, 1981–1989
2 sentences

1981Therefore, they should have been able to search the vehicle and its contents thoroughly without a warrant as part of the automobile exception set forth in Chambers v. Maroney, 399 U.S. 42 , 26 L.Ed.2d 419 , 90 S.Ct. 1975 (1970) and Carroll v. United States, 267 U.S. 132 , 69 L.Ed. 543 , 45 S.Ct. 280 , 39 A.L.R. 790 (1925).

1981Therefore, they should have been able to search the vehicle and its contents thoroughly without a warrant as part of the automobile exception set forth in Chambers v. Maroney, 399 U.S. 42 , 26 L.Ed.2d 419 , 90 S.Ct. 1975 (1970) and Carroll v. United States, 267 U.S. 132 , 69 L.Ed. 543 , 45 S.Ct. 280 , 39 A.L.R. 790 (1925).

13
State v. Valdezgreen
wash · 2009 · cited in 2 Washington opinions naming this issue, 2012–2016
2 sentences

2016State v. Ringer, 100 Wn.2d 686, 700 , 674 P.2d 1240 (1983), overruled in part on other grounds by State v. Stroud, 106 Wn.2d 144 , 720 P.2d 436 (1986), overruled in part on other grounds by State v. Valdez, 167 Wn.2d 761 , 224 P.3d 751 , (2009).

2012Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring); see Buelna Valdez, 167 Wash.2d at 771, 224 P.3d 751 (explaining that the Thornton "search is justified under the Fourth Amendment because there is a reduced expectation of privacy in an automobile and that expectation is outweighed by law enforcement needs heightened by the difficulties arising from an automobile's mobility" (citing Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring))); see also United States v. Arriaza, 641 F.Supp.2d 526, 535 (E.D.Va.2009) (explaining that same considerations as underpin the

12
State v. Valdezgreen
wash · 2009 · cited in 2 Washington opinions naming this issue, 2012–2016
2 sentences

2016State v. Ringer, 100 Wn.2d 686, 700 , 674 P.2d 1240 (1983), overruled in part on other grounds by State v. Stroud, 106 Wn.2d 144 , 720 P.2d 436 (1986), overruled in part on other grounds by State v. Valdez, 167 Wn.2d 761 , 224 P.3d 751 , (2009).

2012Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring); see Buelna Valdez, 167 Wash.2d at 771, 224 P.3d 751 (explaining that the Thornton "search is justified under the Fourth Amendment because there is a reduced expectation of privacy in an automobile and that expectation is outweighed by law enforcement needs heightened by the difficulties arising from an automobile's mobility" (citing Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring))); see also United States v. Arriaza, 641 F.Supp.2d 526, 535 (E.D.Va.2009) (explaining that same considerations as underpin the

12
Thornton v. United Statesgreen
scotus · 2004 · cited in 1 Washington opinions naming this issue, 2012–2012
2 sentences

2012Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring); see Buelna Valdez, 167 Wash.2d at 771, 224 P.3d 751 (explaining that the Thornton "search is justified under the Fourth Amendment because there is a reduced expectation of privacy in an automobile and that expectation is outweighed by law enforcement needs heightened by the difficulties arising from an automobile's mobility" (citing Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring))); see also United States v. Arriaza, 641 F.Supp.2d 526, 535 (E.D.Va.2009) (explaining that same considerations as underpin the

2012Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring); see Buelna Valdez, 167 Wash.2d at 771, 224 P.3d 751 (explaining that the Thornton "search is justified under the Fourth Amendment because there is a reduced expectation of privacy in an automobile and that expectation is outweighed by law enforcement needs heightened by the difficulties arising from an automobile's mobility" (citing Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring))); see also United States v. Arriaza, 641 F.Supp.2d 526, 535 (E.D.Va.2009) (explaining that same considerations as underpin the

11
State v. Pattongreen
wash · 2009 · cited in 1 Washington opinions naming this issue, 2012–2012
2 sentences

2012See Patton, 167 Wn.2d at 386 n.4; Tibbies, 169 Wn.2d at 369 (in context of automobile search where suspect was not arrested; probable cause to search did not justify search of vehicle — “the existence of probable cause, standing alone, does not justify a warrantless search”); Ringer, 100 Wn.2d at 700-01 .

2012See Patton, 167 Wash.2d at 386 n. 4, 219 P.3d 651 ; State v. Tibbles, 169 Wash.2d 364, 369 , 236 P.3d 885 (2010) (in context of automobile search where suspect was not arrested; probable cause to search did not justify search of vehicle—"the existence of probable cause, standing alone, does not justify a warrantless search"); Ringer, 100 Wash.2d at 700-01 , 674 P.2d 1240 .

11
State v. Pattongreen
wash · 2009 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012See Patton, 167 Wash.2d at 386 n. 4, 219 P.3d 651 ; State v. Tibbles, 169 Wash.2d 364, 369 , 236 P.3d 885 (2010) (in context of automobile search where suspect was not arrested; probable cause to search did not justify search of vehicle—"the existence of probable cause, standing alone, does not justify a warrantless search"); Ringer, 100 Wash.2d at 700-01 , 674 P.2d 1240 .

11
United States v. Arriazagreen
vaed · 2009 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring); see Buelna Valdez, 167 Wash.2d at 771, 224 P.3d 751 (explaining that the Thornton "search is justified under the Fourth Amendment because there is a reduced expectation of privacy in an automobile and that expectation is outweighed by law enforcement needs heightened by the difficulties arising from an automobile's mobility" (citing Thornton, 541 U.S. at 631 , 124 S.Ct. 2127 (Scalia, J., concurring))); see also United States v. Arriaza, 641 F.Supp.2d 526, 535 (E.D.Va.2009) (explaining that same considerations as underpin the

11
California v. Carneygreen
scotus · 1985 · cited in 1 Washington opinions naming this issue, 2012–2012
2 sentences

2012The automobile exception allows for a warrantless search of a mobile vehicle when "there is probable cause to believe [the] vehicle contains evidence of criminal activity." Gant, 129 S.Ct. at 1721 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982)); see California v. Carney, 471 U.S. 386 , 105 S.Ct. 2066 , 85 L.Ed.2d 406 (1985) (automobile exception justified based on lower expectation of privacy in a vehicle); Carroll v. United States, 267 U.S. 132, 153-54 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless automobile search supported by probable cause

2012The automobile exception allows for a warrantless search of a mobile vehicle when "there is probable cause to believe [the] vehicle contains evidence of criminal activity." Gant, 129 S.Ct. at 1721 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982)); see California v. Carney, 471 U.S. 386 , 105 S.Ct. 2066 , 85 L.Ed.2d 406 (1985) (automobile exception justified based on lower expectation of privacy in a vehicle); Carroll v. United States, 267 U.S. 132, 153-54 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless automobile search supported by probable cause

11
State v. Portergreen
washctapp · 2000 · cited in 1 Washington opinions naming this issue, 2003–2003
1 sentence

2003See e.g., State v. Porter, 102 Wash.App. 327, 333-34 , 6 P.3d 1245 (2000) (search of vehicle unlawful when suspect arrested 300 feet from vehicle while walking his dog and directed to return to his vehicle).

11
Michigan v. Thomasgreen
scotus · 1982 · cited in 1 Washington opinions naming this issue, 1989–1989
2 sentences

1989See Michigan v. Thomas, 458 U.S. 259, 73 L.

1989See Michigan v. Thomas, 458 U.S. 259, 73 L.

11
State v. Svendrowskigreen
moctapp · 1985 · cited in 1 Washington opinions naming this issue, 1986–1986
1 sentence

1986E.g., State v. Svendrowski, 692 S.W.2d 348, 349 (Mo. Ct. App. 1985); Department of Pub.

11
Chimel v. Californiared
scotus · 1969 · cited in 1 Washington opinions naming this issue, 1982–1982
2 sentences

1982See Arkansas v. Sanders, supra. However, in Belton the court concluded a search incident to an arrest eliminates any privacy interest the arrestee might have in the area immediately around him and allows the police to search any open or closed container within the "passenger compartment." Justice Stewart reasoned that an automobile interior "generally . . . [is] within 'the area into which an arrestee might reach in order to grab a weapon or evidentiary item.'" Belton, 453 U.S. at 460 , 101 S. Ct. at 2864 , citing Chimel v. California, 395 U.S. 752, 763 , 23 L.

1982See Arkansas v. Sanders, supra. However, in Belton the court concluded a search incident to an arrest eliminates any privacy interest the arrestee might have in the area immediately around him and allows the police to search any open or closed container within the "passenger compartment." Justice Stewart reasoned that an automobile interior "generally . . . [is] within 'the area into which an arrestee might reach in order to grab a weapon or evidentiary item.'" Belton, 453 U.S. at 460 , 101 S. Ct. at 2864 , citing Chimel v. California, 395 U.S. 752, 763 , 23 L.

11
South Dakota v. Oppermangreen
scotus · 1976 · cited in 1 Washington opinions naming this issue, 1982–1982
2 sentences

1982See South Dakota v. Opperman, 428 U.S. 364, 367-68 , 49 L.Ed.2d 1000, 1004 , 96 S.Ct. 3092 (1976).

1982See South Dakota v. Opperman, 428 U.S. 364, 367-68 , 49 L.Ed.2d 1000, 1004 , 96 S.Ct. 3092 (1976).

11
New York v. Beltonred
scotus · 1981 · cited in 1 Washington opinions naming this issue, 1982–1982
2 sentences

1982See Arkansas v. Sanders, supra. However, in Belton the court concluded a search incident to an arrest eliminates any privacy interest the arrestee might have in the area immediately around him and allows the police to search any open or closed container within the "passenger compartment." Justice Stewart reasoned that an automobile interior "generally . . . [is] within 'the area into which an arrestee might reach in order to grab a weapon or evidentiary item.'" Belton, 453 U.S. at 460 , 101 S. Ct. at 2864 , citing Chimel v. California, 395 U.S. 752, 763 , 23 L.

1982See Arkansas v. Sanders, supra. However, in Belton the court concluded a search incident to an arrest eliminates any privacy interest the arrestee might have in the area immediately around him and allows the police to search any open or closed container within the "passenger compartment." Justice Stewart reasoned that an automobile interior "generally . . . [is] within 'the area into which an arrestee might reach in order to grab a weapon or evidentiary item.'" Belton, 453 U.S. at 460 , 101 S. Ct. at 2864 , citing Chimel v. California, 395 U.S. 752, 763 , 23 L.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (20)

CaseCitedYears
State v. Stroud red
wash · 1986
2 sentences

1993The State contends that Sergeant Radder's warrantless search of the cab of the pickup was permissible under the automobile exception as defined in State v. Stroud, 106 Wn.2d 144 , 720 P.2d 436 (1986). *269 Mr. Lopez argues that Stroud is factually distinguishable from the instant case 4 and requires that the actual exigencies present in this case be balanced against his constitutional privacy interests to determine whether the automobile exception applies.

1993The State contends that Sergeant Radder's warrantless search of the cab of the pickup was permissible under the automobile exception as defined in State v. Stroud, 106 Wn.2d 144 , 720 P.2d 436 (1986). *269 Mr. Lopez argues that Stroud is factually distinguishable from the instant case 4 and requires that the actual exigencies present in this case be balanced against his constitutional privacy interests to determine whether the automobile exception applies.

41993–2016
State v. Ringer red
wash · 1983
2 sentences

2016State v. Ringer, 100 Wn.2d 686, 700 , 674 P.2d 1240 (1983), overruled in part on other grounds by State v. Stroud, 106 Wn.2d 144 , 720 P.2d 436 (1986), overruled in part on other grounds by State v. Valdez, 167 Wn.2d 761 , 224 P.3d 751 , (2009).

2016State v. Ringer, 100 Wn.2d 686, 700 , 674 P.2d 1240 (1983), overruled in part on other grounds by State v. Stroud, 106 Wn.2d 144 , 720 P.2d 436 (1986), overruled in part on other grounds by State v. Valdez, 167 Wn.2d 761 , 224 P.3d 751 , (2009).

31989–2016
Carroll v. United States green
scotus · 1925
2 sentences

2012The automobile exception allows for a warrantless search of a mobile vehicle when "there is probable cause to believe [the] vehicle contains evidence of criminal activity." Gant, 129 S.Ct. at 1721 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982)); see California v. Carney, 471 U.S. 386 , 105 S.Ct. 2066 , 85 L.Ed.2d 406 (1985) (automobile exception justified based on lower expectation of privacy in a vehicle); Carroll v. United States, 267 U.S. 132, 153-54 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless automobile search supported by probable cause

2012The automobile exception allows for a warrantless search of a mobile vehicle when "there is probable cause to believe [the] vehicle contains evidence of criminal activity." Gant, 129 S.Ct. at 1721 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982)); see California v. Carney, 471 U.S. 386 , 105 S.Ct. 2066 , 85 L.Ed.2d 406 (1985) (automobile exception justified based on lower expectation of privacy in a vehicle); Carroll v. United States, 267 U.S. 132, 153-54 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless automobile search supported by probable cause

31981–2012
United States v. Ross green
scotus · 1982
2 sentences

2012The automobile exception allows for a warrantless search of a mobile vehicle when "there is probable cause to believe [the] vehicle contains evidence of criminal activity." Gant, 129 S.Ct. at 1721 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982)); see California v. Carney, 471 U.S. 386 , 105 S.Ct. 2066 , 85 L.Ed.2d 406 (1985) (automobile exception justified based on lower expectation of privacy in a vehicle); Carroll v. United States, 267 U.S. 132, 153-54 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless automobile search supported by probable cause

2012The automobile exception allows for a warrantless search of a mobile vehicle when "there is probable cause to believe [the] vehicle contains evidence of criminal activity." Gant, 129 S.Ct. at 1721 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982)); see California v. Carney, 471 U.S. 386 , 105 S.Ct. 2066 , 85 L.Ed.2d 406 (1985) (automobile exception justified based on lower expectation of privacy in a vehicle); Carroll v. United States, 267 U.S. 132, 153-54 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless automobile search supported by probable cause

31985–2012
State v. Fladebo green
wash · 1989
2 sentences

2003State v. Fladebo, 113 Wash.2d 388, 397 , 779 P.2d 707 (1989).

2003State v. Fladebo, 113 Wash.2d 388, 397 , 779 P.2d 707 (1989).

22002–2003
State v. Johnston green
washctapp · 2001
2 sentences

2003State v. Johnston, 107 Wash.App. 280, 288 , 28 P.3d 775 (2001), review denied, 145 Wash.2d 1021 , 41 P.3d 483 (2002).

2002State v. Johnston, 107 Wn.

22002–2003
Arizona v. Gant green
scotus · 2009
2 sentences

2012The automobile exception allows for a warrantless search of a mobile vehicle when “there is probable cause to believe [the] vehicle contains evidence of criminal activity.” Gant, 556 U.S. at 347 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S. Ct. 2157 , 72 L.

2012The automobile exception allows for a warrantless search of a mobile vehicle when "there is probable cause to believe [the] vehicle contains evidence of criminal activity." Gant, 129 S.Ct. at 1721 (citing United States v. Ross, 456 U.S. 798, 820-21 , 102 S.Ct. 2157 , 72 L.Ed.2d 572 (1982)); see California v. Carney, 471 U.S. 386 , 105 S.Ct. 2066 , 85 L.Ed.2d 406 (1985) (automobile exception justified based on lower expectation of privacy in a vehicle); Carroll v. United States, 267 U.S. 132, 153-54 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925) (warrantless automobile search supported by probable cause

12012–2012
State v. Tibbles green
wash · 2010
1 sentence

2012See Patton, 167 Wash.2d at 386 n. 4, 219 P.3d 651 ; State v. Tibbles, 169 Wash.2d 364, 369 , 236 P.3d 885 (2010) (in context of automobile search where suspect was not arrested; probable cause to search did not justify search of vehicle—"the existence of probable cause, standing alone, does not justify a warrantless search"); Ringer, 100 Wash.2d at 700-01 , 674 P.2d 1240 .

12012–2012
State v. Tibbles green
wash · 2010
1 sentence

2012See Patton, 167 Wash.2d at 386 n. 4, 219 P.3d 651 ; State v. Tibbles, 169 Wash.2d 364, 369 , 236 P.3d 885 (2010) (in context of automobile search where suspect was not arrested; probable cause to search did not justify search of vehicle—"the existence of probable cause, standing alone, does not justify a warrantless search"); Ringer, 100 Wash.2d at 700-01 , 674 P.2d 1240 .

12012–2012
State v. Johnston green
washctapp · 2001
1 sentence

2003State v. Johnston, 107 Wash.App. 280, 288 , 28 P.3d 775 (2001), review denied, 145 Wash.2d 1021 , 41 P.3d 483 (2002).

12003–2003
State v. Smith green
wash · 1977
2 sentences

1989We have recognized . . . that where police have probable cause to conduct a search, they may do so without a warrant when "they are confronted by emergencies and exigencies which do not permit reasonable time and delay for a judicial officer to evaluate and act upon probable cause applications for warrants by police officers." State v. Smith, 88 Wn.2d 127, 135 , 559 P.2d 970 (1977). 100 Wn.2d at 701 .

1989We have recognized . . . that where police have probable cause to conduct a search, they may do so without a warrant when "they are confronted by emergencies and exigencies which do not permit reasonable time and delay for a judicial officer to evaluate and act upon probable cause applications for warrants by police officers." State v. Smith, 88 Wn.2d 127, 135 , 559 P.2d 970 (1977). 100 Wn.2d at 701 .

11989–1989
Stovall v. Denno green
scotus · 1967
2 sentences

1986In making that analysis, we have considered the following factors set forth in Stovall v. Denno, 388 U.S. 293, 297 , 18 L.

1986In making that analysis, we have considered the following factors set forth in Stovall v. Denno, 388 U.S. 293, 297 , 18 L.

11986–1986
State v. Jordan green
washctapp · 1985
1 sentence

1986In Jordan, 39 Wn.

11986–1986
Cady v. Dombrowski green
scotus · 1973
1 sentence

1982Cady v. Dombrowski, 413 U.S. at 441 .

11982–1982
Almeida-Sanchez v. United States green
scotus · 1973
2 sentences

1981Almeida-Sanchez v. United States, 413 U.S. 266, 269 , 37 L.

1981Almeida-Sanchez v. United States, 413 U.S. 266, 269 , 37 L.

11981–1981
United States v. Chadwick red
scotus · 1977
11981–1981
State v. Fink neutral
mo · 1905
11934–1934
State v. Wasinger green
kan · 1931
11934–1934
State v. Le Masters neutral
wyo · 1927
11934–1934
Eastway v. State neutral
wis · 1926
11934–1934

Where else courts name it

OH 258 (1929–2026) NY 250 (1920–2026) TX 239 (1936–2026) NJ 137 (1966–2026) PA 130 (1932–2026) CA 125 (1919–2026) OR 100 (1930–2026) ID 82 (1976–2026) LA 81 (1960–2025) IL 80 (1974–2026) MA 71 (1934–2026) IN 66 (1929–2025) MI 66 (1940–2026) IA 59 (1979–2026) VA 55 (1939–2025) MD 54 (1968–2026) GA 49 (1927–2022) CO 38 (1971–2026) FL 36 (1971–2025) MO 33 (1914–2025) KS 33 (1982–2024) TN 33 (1926–2026) WI 33 (1925–2025) ND 31 (1981–2026) MN 31 (1979–2025) SC 28 (1986–2026) NE 26 (1944–2026) CT 26 (1968–2025) UT 26 (1980–2022) NC 24 (1938–2026) MS 24 (1968–2025) AL 24 (1957–2010) KY 23 (1969–2026) AZ 17 (1979–2022) DE 15 (1934–2024) DC 15 (1979–2026) WA 14 (1934–2016) NM 14 (1965–2022) ME 13 (1979–2021) WY 11 (1979–2019) AR 11 (1931–2015) OK 11 (1923–2024) WV 10 (1978–2015) NV 9 (1997–2021) RI 8 (1989–2023) VT 8 (1933–2019) HI 7 (1978–2020) MT 6 (1978–2025) NH 5 (1990–2018) SD 5 (2000–2016) VI 4 (2012–2026) AK 3 (1978–1983)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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