By Sarah Roebuck
Police1
SACRAMENTO, Calif. — According to a recent ruling by a California state appeals court, having a valid reason to search the interior of a car for contraband, like witnessing the driver conceal something under the front seat, doesn’t mean police can unlock and search the trunk, the San Fransisco Chronicle reports.
In a 3-0 ruling on Tuesday, the Third District Court of Appeal in Sacramento overturned a previous judge’s decision that permitted Stockton police to present evidence in court regarding a loaded handgun found by an officer in a car trunk. The incident unfolded when an officer noticed an individual exhibiting unusual behavior as he got into the car – walking stiffly and reaching toward his waistband. Subsequently, after a search of the car’s interior yielded no results, the officer decided to open the trunk, where the gun was ultimately discovered.
The court ruled that the case violated the Constitution’s ban on unreasonable searches and seizures.
In April 2021, the case unfolded during a surveillance operation by the police at a funeral, where they anticipated the presence of gang members. During this event, a detective noticed a juvenile who was already on probation and prohibited from possessing firearms. The detective observed the individual clutching his waistband while walking, raising suspicions.
According to the court’s account, the juvenile and Hilario Leal, the owner of the vehicle, approached the car together. The juvenile walked near the trunk before entering through the passenger door. He then laid down on the seat momentarily and got out of the car, no longer exhibiting any signs of stiffness. Following the youth’s departure, the detective conducted a search of the car’s interior, which yielded no results. However, during the search of the trunk, a loaded handgun was discovered. A judge in San Joaquin County deemed the search lawful, leading Leal to enter a no-contest plea for being a felon in possession of a firearm, receiving probation.
Usually, for police to search private property, they are required to obtain a judicial warrant. However, there exists an exception known as the “automobile exception,” recognized by courts, which permits warrantless searches of motor vehicles if officers have reasonable grounds to believe that they will discover contraband or evidence of a crime.
But the appeals court emphasized that for police to search a car trunk, they must possess substantial evidence, meeting the threshold of probable cause, suggesting the possibility of contraband being concealed either in the trunk or somewhere within the vehicle. In this particular case, the court clarified that the probable cause was limited solely to the passenger compartment and did not extend to the trunk.
Due to the ruling, Leal is allowed to withdraw his no-contest plea to the gun possession charge.
https://www.scribd.com/document/661296428/California-v-Leal