Carroll doctrine (Maryland) · Go Syfert
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Carroll doctrine in Maryland

49 Maryland opinions name it 3 courts 1967–2026 6 in the last five years

The cases below were cited by Maryland 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 (34)

CaseFollowedCited
State v. Wallacegreen
md · 2002 · cited in 7 Maryland opinions naming this issue, 2002–2022
2 sentences

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

67
Carroll v. United Statesgreen
scotus · 1925 · cited in 27 Maryland opinions naming this issue, 1967–2026
2 sentences

2026The automobile exception originates from the case of Carroll [v. United States], 267 U.S. 132 [(1925)], and has been referred to the as “the Carroll doctrine.” (Citations omitted). -7- [OFFICER HUFF:] While we were behind it going west on West North Ave, we observed the operator begin to manipulate the cellphone that was mounted to the dash or windshield, and it appeared like he was typing a message or placing a phone call while he was driving the vehicle. [PROSECUTOR:] Okay, why did you think that? . . .

2026The automobile exception originates from the case of Carroll [v. United States], 267 U.S. 132 [(1925)], and has been referred to the as “the Carroll doctrine.” (Citations omitted). -7- [OFFICER HUFF:] While we were behind it going west on West North Ave, we observed the operator begin to manipulate the cellphone that was mounted to the dash or windshield, and it appeared like he was typing a message or placing a phone call while he was driving the vehicle. [PROSECUTOR:] Okay, why did you think that? . . .

527
Wyoming v. Houghtongreen
scotus · 1999 · cited in 9 Maryland opinions naming this issue, 2016–2022
2 sentences

2022As such, the case dealt with the automobile exception to the warrant requirement, also known as the “Carroll doctrine,” which allows an officer to “search an automobile, without a warrant, if he or she has 5 The General Assembly has provided exceptions to this enforcement regime for those who have obtained marijuana “directly or by prescription or order from an authorized provider acting in the course of professional practice.” CR § 5-601(a)(1). 12 probable cause to believe it contains evidence of a crime or contraband goods.” Id. at 468 (citing Carroll v. United States, 267 U.S. 132 (1925); W

2022As such, the case dealt with the automobile exception to the warrant requirement, also known as the “Carroll doctrine,” which allows an officer to “search an automobile, without a warrant, if he or she has 5 The General Assembly has provided exceptions to this enforcement regime for those who have obtained marijuana “directly or by prescription or order from an authorized provider acting in the course of professional practice.” CR § 5-601(a)(1). 12 probable cause to believe it contains evidence of a crime or contraband goods.” Id. at 468 (citing Carroll v. United States, 267 U.S. 132 (1925); W

49
Gadson v. Stategreen
md · 1995 · cited in 4 Maryland opinions naming this issue, 2017–2017
2 sentences

2017See Bowling v. State, 227 Md.App. 460, 469 , 134 A.3d 388 (2016) (citations omitted) ("With respect to the odor of marijuana, the Maryland appellate courts consistently have held that the detection of the odor of marijuana by a trained drug dog establishes probable cause to conduct a warrantless Carroll doctrine search of a vehicle.”); see also Wallace, supra, 372 Md. at 146, 812 A.2d 291 (citing Gadson v. State, 341 Md. 1, 8 , 668 A.2d 22 (1995); In re Montrail M., 87 Md.App. 420 (1991) ("[T]he law is settled that when a properly trained canine alerts to a vehicle indicating the likelihood of

2017See Bowling v. State, 227 Md.App. 460, 469 , 134 A.3d 388 (2016) (citations omitted) ("With respect to the odor of marijuana, the Maryland appellate courts consistently have held that the detection of the odor of marijuana by a trained drug dog establishes probable cause to conduct a warrantless Carroll doctrine search of a vehicle.”); see also Wallace, supra, 372 Md. at 146, 812 A.2d 291 (citing Gadson v. State, 341 Md. 1, 8 , 668 A.2d 22 (1995); In re Montrail M., 87 Md.App. 420 (1991) ("[T]he law is settled that when a properly trained canine alerts to a vehicle indicating the likelihood of

44
United States v. Rossgreen
scotus · 1982 · cited in 7 Maryland opinions naming this issue, 1991–2022
2 sentences

2017In Carroll , the Court did not address the scope of the search that is permissible, and it took many years before the Supreme Court re-examined the automobile exception in 1982 in Ross, supra, 456 U.S. 798 , 102 S.Ct. 2157 . 13 The subsequent decisional detours under and around the Carroll doctrine are particularly instructive in considering the present case involv *262 ing the search and arrest of a passenger, followed by the search of a vehicle.

2017In Carroll , the Court did not address the scope of the search that is permissible, and it took many years before the Supreme Court re-examined the automobile exception in 1982 in Ross, supra, 456 U.S. 798 , 102 S.Ct. 2157 . 13 The subsequent decisional detours under and around the Carroll doctrine are particularly instructive in considering the present case involv *262 ing the search and arrest of a passenger, followed by the search of a vehicle.

27
Bowling v. Stategreen
mdctspecapp · 2016 · cited in 6 Maryland opinions naming this issue, 2017–2017
2 sentences

2017In Bowling, 227 Md.App. at 476 , 134 A.3d at 398 , the Court of Special Appeals concluded that the decriminalization of possession of less than ten grams of marijuana did not alter the status of marijuana as contraband in Maryland, and that a narcotics dog’s alert provides probable cause to search a vehicle pursuant to the Carroll doctrine.

2017In Bowling, 227 Md.App. at 476 , 134 A.3d at 398 , the Court of Special Appeals concluded that the decriminalization of possession of less than ten grams of marijuana did not alter the status of marijuana as contraband in Maryland, and that a narcotics dog’s alert provides probable cause to search a vehicle pursuant to the Carroll doctrine.

26
California v. Acevedogreen
scotus · 1991 · cited in 5 Maryland opinions naming this issue, 2005–2022
2 sentences

2022Thus, under the Carroll doctrine, police may conduct a warrantless search of “an automobile and the containers within it where they have probable cause to believe contraband or evidence [of a crime] is contained.” California v. Acevedo, 500 U.S. 565, 580 (1991).18 The justifications for this exception are the “ready mobility” and “pervasive and continuing governmental regulation” of vehicles, Collins, 138 S. Ct. at 1669-70 , which has reduced individuals’ expectation of privacy in automobiles, Pennsylvania v. Labron, 518 U.S. 938, 940 (1996).

2022Thus, under the Carroll doctrine, police may conduct a warrantless search of “an automobile and the containers within it where they have probable cause to believe contraband or evidence [of a crime] is contained.” California v. Acevedo, 500 U.S. 565, 580 (1991).18 The justifications for this exception are the “ready mobility” and “pervasive and continuing governmental regulation” of vehicles, Collins, 138 S. Ct. at 1669-70 , which has reduced individuals’ expectation of privacy in automobiles, Pennsylvania v. Labron, 518 U.S. 938, 940 (1996).

25
Grant v. Stategreen
md · 2016 · cited in 3 Maryland opinions naming this issue, 2017–2019
2 sentences

2019Grant v. State, 449 Md. 1 , 16 n.3, 141 A.3d 138 , 147 n.3 (2016). 13 To conduct a lawful frisk of an individual, a law enforcement officer must be rightly in the presence of the individual to be frisked.

2019Grant v. State, 449 Md. 1 , 16 n.3, 141 A.3d 138 , 147 n.3 (2016). 13 To conduct a lawful frisk of an individual, a law enforcement officer must be rightly in the presence of the individual to be frisked.

23
Robinson, Williams & Spriggs v. Stategreen
md · 2017 · cited in 3 Maryland opinions naming this issue, 2017–2018
2 sentences

2018In analyzing, and ultimately rejecting that argument, the Court relied on the Carroll doctrine, "the automobile exception to the warrant requirement." Id. at 111 , 152 A.3d 661 (citing Carroll , 267 U.S. at 153 , 45 S.Ct. 280 ) (emphasis added).

2018In analyzing, and ultimately rejecting that argument, the Court relied on the Carroll doctrine, "the automobile exception to the warrant requirement." Id. at 111 , 152 A.3d 661 (citing Carroll , 267 U.S. at 153 , 45 S.Ct. 280 ) (emphasis added).

23
Wilkes v. Stategreen
md · 2001 · cited in 3 Maryland opinions naming this issue, 2002–2017
2 sentences

2017Accord Wilkes, supra, 364 Md. at 586-87, 774 A.2d 420 (“once a drug dog has alerted a trooper ‘to the presence of illegal drugs in a vehicle, sufficient probable cause exist[s] to support a warrantless search of [a vehicle],’ ” quoting Gadson v. State, 341 Md. 1, 8 , 668 A.2d 22 (1995)); Bowling v. State, 227 Md.App. 460, 469, 476 , 134 A.3d 388 (2016) (“the Maryland appellate courts consistently have held that the detection of the odor of marijuana by a trained drug dog establishes probable cause to conduct a warrantless Carroll doctrine search of a vehicle,” and the partial decriminalization

2016Wilkes v. State, 364 Md. 554, 586-87 , 774 A.2d 420 (2001); Pyon v. State, 222 Md.App. 412, 439 , 112 A.3d 1130 (2015).

23
California v. Carneygreen
scotus · 1985 · cited in 2 Maryland opinions naming this issue, 2020–2022
2 sentences

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

2022But “the scope of the automobile exception extends no further than the automobile itself,” Collins, 138 S. Ct. at 1671 , and probable cause to search a vehicle does not automatically provide probable cause to search an occupant of the vehicle, State v. Wallace, 372 Md. 137, 144 (2002). 18 “Although typically described as the automobile exception to the Fourth Amendment warrant requirement, the Carroll exception also applies to searches of other vehicles.” Lewis v. State, 470 Md. 1 , 20 n.6 (2020); see also Carroll, 267 U.S. at 153 (characterizing “ship[s], motor boat[s], wagon[s], [and] automo

22
Chambers v. Maroneygreen
scotus · 1970 · cited in 5 Maryland opinions naming this issue, 1971–2005
2 sentences

1975In rejecting application of the Carroll doctrine, the *271 Coolidge Court, quoting in part from Chambers v. Maroney, 399 U. S. 42, 51 , 90 S. Ct. 1975 , 26 L.Ed.2d 419 (1970), emphasized that exigent circumstances arise when the car is “ ‘movable, the occupants are alerted, and the car’s contents may never be found again if a warrant must be obtained.’ ‘[T]he opportunity to search is fleeting ....’” 403 U. S. at 460 .

1975In rejecting application of the Carroll doctrine, the *271 Coolidge Court, quoting in part from Chambers v. Maroney, 399 U. S. 42, 51 , 90 S. Ct. 1975 , 26 L.Ed.2d 419 (1970), emphasized that exigent circumstances arise when the car is “ ‘movable, the occupants are alerted, and the car’s contents may never be found again if a warrant must be obtained.’ ‘[T]he opportunity to search is fleeting ....’” 403 U. S. at 460 .

15
Wilkes v. Stategreen
md · 2001 · cited in 3 Maryland opinions naming this issue, 2002–2017
2 sentences

2017Accord Wilkes, supra, 364 Md. at 586-87, 774 A.2d 420 (“once a drug dog has alerted a trooper ‘to the presence of illegal drugs in a vehicle, sufficient probable cause exist[s] to support a warrantless search of [a vehicle],’ ” quoting Gadson v. State, 341 Md. 1, 8 , 668 A.2d 22 (1995)); Bowling v. State, 227 Md.App. 460, 469, 476 , 134 A.3d 388 (2016) (“the Maryland appellate courts consistently have held that the detection of the odor of marijuana by a trained drug dog establishes probable cause to conduct a warrantless Carroll doctrine search of a vehicle,” and the partial decriminalization

2016Wilkes v. State, 364 Md. 554, 586-87 , 774 A.2d 420 (2001); Pyon v. State, 222 Md.App. 412, 439 , 112 A.3d 1130 (2015).

13
Florida v. Harrisgreen
scotus · 2013 · cited in 2 Maryland opinions naming this issue, 2017–2022
2 sentences

2022Whereas the search incident to arrest exception requires probable cause to believe that the arrested person has committed a crime, see supra Part II.A.1, the Carroll doctrine only requires probable cause to believe that the vehicle contains contraband or evidence of a crime, Florida v. Harris, 568 U.S. 237, 243 (2013).

2022Whereas the search incident to arrest exception requires probable cause to believe that the arrested person has committed a crime, see supra Part II.A.1, the Carroll doctrine only requires probable cause to believe that the vehicle contains contraband or evidence of a crime, Florida v. Harris, 568 U.S. 237, 243 (2013).

12
State v. Cabralgreen
mdctspecapp · 2004 · cited in 2 Maryland opinions naming this issue, 2017–2017
2 sentences

2017The Carroll doctrine exception, which allows the warrantless search of a vehicle based on probable cause, is based on "the exigencies associated with the mobility of a vehicle, and the diminished expectation of privacy with regard to a vehicle." Fair v. State, 198 Md.App. 1, 11 , 16 A.3d 211 (2011) (quoting State v. Cabral, 159 Md.App. 354, 372-73 , 859 A.2d 285 (2004)). 7 .

2017The Carroll doctrine exception, which allows the warrantless search of a vehicle based on probable cause, is based on "the exigencies associated with the mobility of a vehicle, and the diminished expectation of privacy with regard to a vehicle." Fair v. State, 198 Md.App. 1, 11 , 16 A.3d 211 (2011) (quoting State v. Cabral, 159 Md.App. 354, 372-73 , 859 A.2d 285 (2004)). 7 .

12
Maryland v. Pringlegreen
scotus · 2003 · cited in 1 Maryland opinions naming this issue, 2022–2022
11
Pennsylvania v. Labrongreen
scotus · 1996 · cited in 1 Maryland opinions naming this issue, 2022–2022
11
Lewis v. Stategreen
mdctspecapp · 2018 · cited in 1 Maryland opinions naming this issue, 2020–2020
11
Bailey v. Stategreen
md · 2010 · cited in 1 Maryland opinions naming this issue, 2019–2019
11
Wengert v. Stategreen
md · 2001 · cited in 1 Maryland opinions naming this issue, 2016–2016
11
United States v. Warren D. Turnergreen
cadc · 1997 · cited in 1 Maryland opinions naming this issue, 2005–2005
11
Humphrey v. Stategreen
mdctspecapp · 1978 · cited in 1 Maryland opinions naming this issue, 2000–2000
11
Almeida-Sanchez v. United Statesgreen
scotus · 1973 · cited in 1 Maryland opinions naming this issue, 2000–2000
11
Manno v. Stategreen
mdctspecapp · 1993 · cited in 1 Maryland opinions naming this issue, 1999–1999
11
Crown Oil and Wax Co. of Delaware, Inc. v. Glen Construction Co. of Virginia, Inc.green
md · 1990 · cited in 1 Maryland opinions naming this issue, 1994–1994
11
Atlantic Mutual Insurance v. Kenneygreen
md · 1991 · cited in 1 Maryland opinions naming this issue, 1994–1994
11
Dixon v. Stategreen
mdctspecapp · 1974 · cited in 1 Maryland opinions naming this issue, 1994–1994
11
Squire v. Stategreen
md · 1977 · cited in 1 Maryland opinions naming this issue, 1994–1994
11
Brice v. Stategreen
md · 1969 · cited in 1 Maryland opinions naming this issue, 1994–1994
11
Basoff v. Stategreen
md · 1977 · cited in 1 Maryland opinions naming this issue, 1994–1994
11
Texas v. Whitegreen
scotus · 1975 · cited in 1 Maryland opinions naming this issue, 1989–1989
11
Michigan v. Thomasgreen
scotus · 1982 · cited in 1 Maryland opinions naming this issue, 1989–1989
11
United States v. Robinsongreen
scotus · 1973 · cited in 1 Maryland opinions naming this issue, 1975–1975
11
Johnson v. Stategreen
mdctspecapp · 1970 · cited in 1 Maryland opinions naming this issue, 1970–1970
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Maryland v. Dysongreen
scotus · 1999 · cited in 2 Maryland opinions naming this issue, 2000–2000
2 sentences

2000But cf. Dyson, 527 U.S. at 466-67 , 119 S.Ct. 2013 (holding that the Carroll doctrine has no separate exigency requirement).

2000But cf. Dyson, 527 U.S. at 466-67 , 119 S.Ct. 2013 (holding that the Carroll doctrine has no separate exigency requirement).

12

Also cited on this issue (43)

CaseCitedYears
State v. Bell green
md · 1994
2 sentences

2022Thus, we can find no error in that court’s limitation of the first Carroll doctrine search to the seizure of a single vial. 334 Md. at 186 .

2022Thus, we can find no error in that court’s limitation of the first Carroll doctrine search to the seizure of a single vial. 334 Md. at 186 .

32010–2022
Arizona v. Gant green
scotus · 2009
2 sentences

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

32016–2019
Kentucky v. King green
scotus · 2011
2 sentences

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

32016–2019
Horton v. California green
scotus · 1990
2 sentences

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

32016–2019
Warden, Maryland Penitentiary v. Hayden green
scotus · 1967
2 sentences

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

32016–2019
Schneckloth v. Bustamonte green
scotus · 1973
2 sentences

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

32016–2019
Terry v. Ohio green
scotus · 1968
2 sentences

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

2019As such, a law enforcement officer may legitimately frisk an individual if the officer has reasonable articulable suspicion that the person with whom the officer is dealing is armed and dangerous.13 Id. at 367 , 987 A.2d at 83 (citations omitted). (. . . continued) 129 S. Ct. 1710 , 173 L.Ed.2d 485 (2009)); 2) hot pursuit (Warden v. Hayden, 387 U.S. 294 , 87 S. Ct. 1642 , 18 L.Ed.2d 782 (1967)); 3) the plain view doctrine (Horton v. California, 496 U.S. 128 , 110 S. Ct. 2301 , 110 L.Ed.2d 112 (1990)); 4) the Carroll doctrine (Carroll v. United States, 267 U.S. 132 , 45 S. Ct. 280 , 69 L.Ed. 54

32016–2019
Robeson v. State green
md · 1979
2 sentences

2010In support of its argument, the State cites Robeson v. State, 285 Md. 498 , 403 A.2d 1221 (1979)....

2010In support of its argument, the State cites Robeson v. State, 285 Md. 498 , 403 A.2d 1221 (1979)....

21994–2010
Whiting v. State green
mdctspecapp · 1999
2 sentences

2007We have stated that “[m]any of the cases applying the Carroll doctrine have found probable cause to search the trunk of a motor vehicle based on evidence apparent to a police officer after a lawful search of the passenger compartment of the vehicle.” Whiting v. State, 125 Md.App. 404, 415 , 725 A.2d 623 (1999) (and cases cited therein).

2007We have stated that “[m]any of the cases applying the Carroll doctrine have found probable cause to search the trunk of a motor vehicle based on evidence apparent to a police officer after a lawful search of the passenger compartment of the vehicle.” Whiting v. State, 125 Md.App. 404, 415 , 725 A.2d 623 (1999) (and cases cited therein).

22005–2007
Berry v. State green
mdctspecapp · 2004
2 sentences

2006Writing for this Court in Berry v. State, 155 Md.App. 144, 176 , 843 A.2d 93 , cert. denied, 381 Md. 674 , 851 A.2d 594 (2004), Judge Barbera explained: The United States Supreme Court, in a series of cases harkening back almost 80 years, has recognized an exception to the warrant requirement that allows the police, when they have probable cause to believe a vehicle contains contraband or evidence of a crime, to search the vehicle for that contraband or evidence of a crime and seize it, without a warrant.

2006Writing for this Court in Berry v. State, 155 Md.App. 144, 176 , 843 A.2d 93 , cert. denied, 381 Md. 674 , 851 A.2d 594 (2004), Judge Barbera explained: The United States Supreme Court, in a series of cases harkening back almost 80 years, has recognized an exception to the warrant requirement that allows the police, when they have probable cause to believe a vehicle contains contraband or evidence of a crime, to search the vehicle for that contraband or evidence of a crime and seize it, without a warrant.

22004–2006
Brown v. State green
mdctspecapp · 2000
2 sentences

2006“If a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment ... permits police to search the vehicle without more.” This exception was derived from Carroll v. United States, 267 U.S. 132 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925), and has since been referred to as the “Carroll doctrine.” 132 Md.App. at 261, 752 A.2d 620 (internal citations and footnote omitted).

2004“If a car is readily mobile and probable cause exists to believe it *373 contains contraband, the Fourth Amendment ... permits police to search the vehicle without more.” This exception was derived from Carroll v. United States, 267 U.S. 132 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925), and has since been referred to as the “Carroll doctrine.” 132 Md.App. at 261, 752 A.2d 620 (internal citations and footnote omitted).

22004–2006
Nathan v. State green
md · 2002
2 sentences

2005As this Court noted in Whiting v. State, 125 Md.App. 404, 415 , 725 A.2d 623 (1999), “Many of the cases applying the Carroll doctrine have found probable cause to search the trunk of a *249 motor vehicle based on evidence apparent to a police officer after a search of the passenger compartment of the vehicle.” Cf. Nathan, supra, 370 Md. at 666 , 805 A.2d 1086 (evidence of a hidden compartment in ceiling of van, in combination with suspicious behavior, supported probable cause to search the vehicle for contraband); State v. James, supra, 87 Md.App. at 42 , 589 A.2d 81 (evidence of drugs discove

2005As this Court noted in Whiting v. State, 125 Md.App. 404, 415 , 725 A.2d 623 (1999), “Many of the cases applying the Carroll doctrine have found probable cause to search the trunk of a *249 motor vehicle based on evidence apparent to a police officer after a search of the passenger compartment of the vehicle.” Cf. Nathan, supra, 370 Md. at 666 , 805 A.2d 1086 (evidence of a hidden compartment in ceiling of van, in combination with suspicious behavior, supported probable cause to search the vehicle for contraband); State v. James, supra, 87 Md.App. at 42 , 589 A.2d 81 (evidence of drugs discove

22002–2005
Dyson v. State red
mdctspecapp · 1998
2 sentences

2000Dyson, 122 Md.App. at 428 , 712 A.2d 573 .

2000Dyson, 122 Md.App. at 428 , 712 A.2d 573 .

21999–2000
United States v. Johns green
scotus · 1985
2 sentences

1989In United States v. Johns, 469 U.S. 478, 484 , 105 S.Ct. 881, 885 , 83 L.Ed.2d 890 (1985), the Court said, of a search authorized by authority of the Carroll doctrine, that: There is no requirement that the warrantless search of a vehicle occur contemporaneously with its lawful seizure.

1989In United States v. Johns, 469 U.S. 478, 484 , 105 S.Ct. 881, 885 , 83 L.Ed.2d 890 (1985), the Court said, of a search authorized by authority of the Carroll doctrine, that: There is no requirement that the warrantless search of a vehicle occur contemporaneously with its lawful seizure.

21989–1993
Howell v. State green
md · 1974
21975–1977
Coolidge v. New Hampshire green
scotus · 1971
21975–1977
Collins v. Virginia green
scotus · 2018
12022–2022
Lewis v. State green
md · 2020
12022–2022
Pacheco v. State green
md · 2019
12022–2022
Jackson v. State green
mdctspecapp · 2010
12017–2017
Texas v. Brown green
scotus · 1983
12017–2017
In Re Montrail M. green
mdctspecapp · 1991
12017–2017
Fair v. State green
mdctspecapp · 2011
12017–2017
Wilson v. State green
md · 2009
12016–2016
Pyon v. State green
mdctspecapp · 2015
12016–2016
Illinois v. Caballes green
scotus · 2005
12015–2015
Carroll v. Housing Opportunities Commission green
md · 1986
12012–2012
State v. James green
mdctspecapp · 1991
12005–2005
Doering v. State green
md · 1988
12002–2002
Commonwealth v. Jiminez green
massappct · 1986
11999–1999
Bell v. State green
mdctspecapp · 1993
11994–1994
Banks v. State green
md · 1954
11994–1994
Robeson v. Maryland green
scotus · 1980
11994–1994
Fowler v. State neutral
mdctspecapp · 1989
11993–1993
Arkansas v. Sanders red
scotus · 1979
11993–1993
Barrow v. State green
mdctspecapp · 1984
11989–1989
Malcolm v. State green
mdctspecapp · 1987
11989–1989
Malcolm v. State green
md · 1988
11989–1989
United States v. Ventresca green
scotus · 1965
11988–1988
Illinois v. Gates green
scotus · 1983
11987–1987

Statutes the citing opinions construe

MD § Md. Code Ann., Crim. Proc. § 2-202 (3) USC § 21u.s.c.844 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MD 49 (1967–2026) TX 17 (1939–2021) FL 17 (1969–2022) AL 16 (1972–2018) CA 12 (1973–2013) GA 8 (1976–2007) IA 7 (1971–2015) LA 7 (1962–1987) VA 7 (1997–2026) WV 5 (1980–1982) NJ 4 (1979–1989) MA 4 (1975–2001) MT 4 (1992–2025) OH 4 (2004–2024) MI 4 (1974–2022) IL 4 (1981–2022) MS 4 (1972–2025) WI 3 (2001–2023) HI 3 (1970–2020) MN 3 (1974–2014) PA 3 (2004–2024) IN 3 (1995–2004) MO 3 (1991–2000) NY 2 (1979–2024) SC 2 (2004–2007) DC 2 (1974–1992) AZ 2 (1977–1984) NE 2 (1991–2014) NC 2 (2021–2021) ID 2 (1991–2001) KS 2 (2018–2020) KY 2 (1971–2001)

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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