U.S. v. Hays

In prosecution on drug distribution charge, Dist. Ct. did not err in denying defendant’s motion to suppress drugs seized from defendant’s car during traffic stop. Record showed that: (1) in October of 2019, police received tip that individual known as “Chuck” was distributing drugs from Cadillac; (2) on October 15, 2019, police saw individual named “Chuck” drive same Cadillac and commit traffic offenses; (3) police stopped Cadillac and noticed passenger, who had outstanding arrest warrant, attempt to hide methamphetamine pipe and shove something in her mouth; (4) passenger spit out plastic object that officer believed to contain methamphetamine; (5) police then searched Cadillac, did not find drugs, but did find screwdriver in center console, which they believed could be used to hide drugs in vehicle’s compartments; and (6) police then used screwdriver to search under Cadillac’s hood and found bag of methamphetamine in air filter housing box. Dist. Ct. properly denied defendant’s motion to suppress instant seizure, where automobile exception to Fourth Amendment’s warrant requirement allows police to conduct warrantless search of vehicle, where, as here, there was probable cause to believe that vehicle contained contraband or evidence of illegal activity. Fact that defendant himself had not been observed attempting to hide pipe or possess methamphetamine did not require different result.