mobility requirement (Oregon) · Go Syfert
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mobility requirement in Oregon

7 Oregon opinions name it 1 courts 1992–2017 0 in the last five years

The cases below were cited by Oregon 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 (4)

CaseFollowedCited
State v. Browngreen
or · 1986 · cited in 2 Oregon opinions naming this issue, 1992–2017
2 sentences

1992In interpreting the mobility requirement of the automobile exception, I urge that we be mindful that the principal rationale for the exception is to prevent evidence of criminal activity from being "quickly moved out of the locality or jurisdiction in which the warrant must be sought." Carroll v. United States, 267 U.S. 132, 153 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925); see State v. Brown, 301 Or. 268 , 721 P.2d 1357 (1986).

1992In interpreting the mobility requirement of the automobile exception, I urge that we be mindful that the principal rationale for the exception is to prevent evidence of criminal activity from being "quickly moved out of the locality or jurisdiction in which the warrant must be sought." Carroll v. United States, 267 U.S. 132, 153 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925); see State v. Brown, 301 Or. 268 , 721 P.2d 1357 (1986).

12
State v. Getzelmangreen
orctapp · 2002 · cited in 2 Oregon opinions naming this issue, 2002–2008
2 sentences

2008Because the stop of [the] vehicle had not been converted to an impoundment, the mobility requirement of the automobile exception was satisfied.” 178 Or App at 601 (emphasis in original).

2002Because the stop of [the car] had not been converted to an impoundment, the mobility requirement of the automobile exception was satisfied.” Id. (emphasis omitted).

12
State v. Cromwellgreen
orctapp · 1991 · cited in 1 Oregon opinions naming this issue, 2002–2002
2 sentences

2002See State v. Cromwell, 109 Or App 654, 659 , 820 P2d 888 (1991) (car was sufficiently mobile to justify a warrantless search where the defendant was in his truck and the “fact that defendant had not yet turned the key was merely fortuitous”); Burr, 136 Or App at 149 (in light of rationale for the rule, a vehicle is “occupied and operable” where defendants are standing immediately outside truck parked along a public highway when police encounter it).

2002See State v. Cromwell, 109 Or.

11
State v. Burrgreen
orctapp · 1995 · cited in 1 Oregon opinions naming this issue, 2002–2002
1 sentence

2002See State v. Cromwell, 109 Or App 654, 659 , 820 P2d 888 (1991) (car was sufficiently mobile to justify a warrantless search where the defendant was in his truck and the “fact that defendant had not yet turned the key was merely fortuitous”); Burr, 136 Or App at 149 (in light of rationale for the rule, a vehicle is “occupied and operable” where defendants are standing immediately outside truck parked along a public highway when police encounter it).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Carroll v. United States green
scotus · 1925
2 sentences

1992In interpreting the mobility requirement of the automobile exception, I urge that we be mindful that the principal rationale for the exception is to prevent evidence of criminal activity from being "quickly moved out of the locality or jurisdiction in which the warrant must be sought." Carroll v. United States, 267 U.S. 132, 153 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925); see State v. Brown, 301 Or. 268 , 721 P.2d 1357 (1986).

1992In interpreting the mobility requirement of the automobile exception, I urge that we be mindful that the principal rationale for the exception is to prevent evidence of criminal activity from being "quickly moved out of the locality or jurisdiction in which the warrant must be sought." Carroll v. United States, 267 U.S. 132, 153 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925); see State v. Brown, 301 Or. 268 , 721 P.2d 1357 (1986).

21992–2017
State v. Kurokawa-Lasciak green
or · 2011
2 sentences

2015The Supreme Court’s opinion in Kurokawa-Lasciak is dispositive. 351 Or at 179 .

2013The state argues that, under Kurokawa-Lasciak , to meet the mobility requirement, it must show only that a vehicle is “mobile at the time that police encounter it in connection with a crime.” Id. at 192 .

22013–2015
State v. Andersen green
or · 2017
1 sentence

2017Further, the court explained in Brown (and recently repeated in Andersen, 361 Or at 194 ) that the exigency that constitutionally allows police officers to search a mobile vehicle without a warrant arises because “‘the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought.’” 301 Or at 275 (quoting Carroll, 267 US at 153 ).

12017–2017

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