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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.
| Case | Followed | Cited |
|---|---|---|
State v. Wallacegreen2 sentences2022But “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 | 6 | 7 |
Carroll v. United Statesgreen2 sentences2026The 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? . . . | 5 | 27 |
Wyoming v. Houghtongreen2 sentences2022As 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 | 4 | 9 |
Gadson v. Stategreen2 sentences2017See 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 | 4 | 4 |
United States v. Rossgreen2 sentences2017In 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. | 2 | 7 |
Bowling v. Stategreen2 sentences2017In 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. | 2 | 6 |
California v. Acevedogreen2 sentences2022Thus, 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). | 2 | 5 |
Grant v. Stategreen2 sentences2019Grant 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. | 2 | 3 |
Robinson, Williams & Spriggs v. Stategreen2 sentences2018In 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). | 2 | 3 |
Wilkes v. Stategreen2 sentences2017Accord 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). | 2 | 3 |
California v. Carneygreen2 sentences2022But “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 | 2 | 2 |
Chambers v. Maroneygreen2 sentences1975In 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 . | 1 | 5 |
Wilkes v. Stategreen2 sentences2017Accord 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). | 1 | 3 |
Florida v. Harrisgreen2 sentences2022Whereas 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). | 1 | 2 |
State v. Cabralgreen2 sentences2017The 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 . | 1 | 2 |
| Maryland v. Pringlegreen | 1 | 1 |
| Pennsylvania v. Labrongreen | 1 | 1 |
| Lewis v. Stategreen | 1 | 1 |
| Bailey v. Stategreen | 1 | 1 |
| Wengert v. Stategreen | 1 | 1 |
| United States v. Warren D. Turnergreen | 1 | 1 |
| Humphrey v. Stategreen | 1 | 1 |
| Almeida-Sanchez v. United Statesgreen | 1 | 1 |
| Manno v. Stategreen | 1 | 1 |
| Crown Oil and Wax Co. of Delaware, Inc. v. Glen Construction Co. of Virginia, Inc.green | 1 | 1 |
| Atlantic Mutual Insurance v. Kenneygreen | 1 | 1 |
| Dixon v. Stategreen | 1 | 1 |
| Squire v. Stategreen | 1 | 1 |
| Brice v. Stategreen | 1 | 1 |
| Basoff v. Stategreen | 1 | 1 |
| Texas v. Whitegreen | 1 | 1 |
| Michigan v. Thomasgreen | 1 | 1 |
| United States v. Robinsongreen | 1 | 1 |
| Johnson v. Stategreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Maryland v. Dysongreen2 sentences2000But 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). | 1 | 2 |
| Case | Cited | Years |
|---|---|---|
State v. Bell
green
2 sentences2022Thus, 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 . | 3 | 2010–2022 |
Arizona v. Gant
green
2 sentences2019As 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 | 3 | 2016–2019 |
Kentucky v. King
green
2 sentences2019As 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 | 3 | 2016–2019 |
Horton v. California
green
2 sentences2019As 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 | 3 | 2016–2019 |
Warden, Maryland Penitentiary v. Hayden
green
2 sentences2019As 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 | 3 | 2016–2019 |
Schneckloth v. Bustamonte
green
2 sentences2019As 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 | 3 | 2016–2019 |
Terry v. Ohio
green
2 sentences2019As 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 | 3 | 2016–2019 |
Robeson v. State
green
2 sentences2010In 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).... | 2 | 1994–2010 |
Whiting v. State
green
2 sentences2007We 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). | 2 | 2005–2007 |
Berry v. State
green
2 sentences2006Writing 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. | 2 | 2004–2006 |
Brown v. State
green
2 sentences2006“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). | 2 | 2004–2006 |
Nathan v. State
green
2 sentences2005As 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 | 2 | 2002–2005 |
Dyson v. State
red
2 sentences2000Dyson, 122 Md.App. at 428 , 712 A.2d 573 . 2000Dyson, 122 Md.App. at 428 , 712 A.2d 573 . | 2 | 1999–2000 |
United States v. Johns
green
2 sentences1989In 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. | 2 | 1989–1993 |
| Howell v. State green | 2 | 1975–1977 |
| Coolidge v. New Hampshire green | 2 | 1975–1977 |
| Collins v. Virginia green | 1 | 2022–2022 |
| Lewis v. State green | 1 | 2022–2022 |
| Pacheco v. State green | 1 | 2022–2022 |
| Jackson v. State green | 1 | 2017–2017 |
| Texas v. Brown green | 1 | 2017–2017 |
| In Re Montrail M. green | 1 | 2017–2017 |
| Fair v. State green | 1 | 2017–2017 |
| Wilson v. State green | 1 | 2016–2016 |
| Pyon v. State green | 1 | 2016–2016 |
| Illinois v. Caballes green | 1 | 2015–2015 |
| Carroll v. Housing Opportunities Commission green | 1 | 2012–2012 |
| State v. James green | 1 | 2005–2005 |
| Doering v. State green | 1 | 2002–2002 |
| Commonwealth v. Jiminez green | 1 | 1999–1999 |
| Bell v. State green | 1 | 1994–1994 |
| Banks v. State green | 1 | 1994–1994 |
| Robeson v. Maryland green | 1 | 1994–1994 |
| Fowler v. State neutral | 1 | 1993–1993 |
| Arkansas v. Sanders red | 1 | 1993–1993 |
| Barrow v. State green | 1 | 1989–1989 |
| Malcolm v. State green | 1 | 1989–1989 |
| Malcolm v. State green | 1 | 1989–1989 |
| United States v. Ventresca green | 1 | 1988–1988 |
| Illinois v. Gates green | 1 | 1987–1987 |
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.
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.