People v. Byrd 

(Court opinion corrected 12/5/11.) Defendant was charged with possession of numerous packets of heroin recovered from a magnetic box officers seized from under the chassis of the car he was driving after arrest for driving without a valid license. Court found probable cause was not established from a single street transaction testified to by officer; court gave little weight to anonymous phone call that triggered narcotics investigation. Cause remanded for new suppression hearing where parties may develop the facts in light of Arizona v. Gant, a U.S. Supreme Court case decided after suppression hearing occurred and which clarified when vehicle search may be authorized as incident to arrest of recent occupant. (McBRIDE, concurring; R.E. GORDON, dissenting.)