Maryland v. Dyson, 527 U.S. 465 (1999)

Maryland v. Dyson


No. 98-1062


Decided June 21, 1999
527 U.S. 465

ON PETITION FOR WRIT OF CERTIORARI TO THE COURT OF
SPECIAL APPEALS OF MARYLAND

Syllabus

After receiving a tip from a reliable informant, sheriff’s deputies stopped and searched respondent’s vehicle and found 23 grams of cocaine in the trunk. The Court of Special Appeals reversed his drug conviction, holding that, in order for the automobile exception to the Fourth Amendment’s warrant erequirement to apply, there must not only be probable cause to believe that evidence of a crime is contained in the car, but also a separate finding of exigency precluding the police from obtaining a warrant.

Held: the automobile exception does not require a separate finding of exigency in addition to a finding of probable cause. This Court’s established precedent makes clear that, in cases where there was probable cause to search a vehicle, a search is not unreasonable if based on facts that would justify issuing a warrant, even though a warrant has not been actually obtained. E.g., United States v. Ross, 456 U.S. 798, 809. Here, the lower court found "abundant probable cause" that the car contained contraband, which alone satisfies the warrant requirement’s automobile exception.

Certiorari granted; 122 Md.App. 413, 712 A.2d 573, reversed.