People v. Oliver

Defendant was stopped for following too closely in construction zone, then consented to search of interior of his vehicle; officer requested that Defendant and his passenger stand at either end of car during search. Ten to fifteen minutes later, officer asked for consent to search trunk, and Defendant consented; officer found plastic bag of cocaine. Defendant was not seized within meaning of Fourth Amendment when officer asked to search trunk. A person's agreement to wait during consensual search is inherent in his consent to search, and the search time is not an improper seizure. Thus, consent to search trunk was valid and search did not violate Fourth Amendment.