## Facts

- A St. Mary’s County, Maryland, sheriff’s deputy received a tip from a reliable confidential informant that Kevin Darnell Dyson had traveled to New York to buy drugs and would return later that day in a rented red Toyota with a specified license plate and a large quantity of cocaine.
- The deputy corroborated key details, including that the plate matched a red Toyota Corolla rented to Dyson, who was known locally as a drug dealer.
- Around 1:00 a.m. the next day, deputies stopped Dyson upon his return in the described rental car.
- Without obtaining a warrant, officers searched the vehicle and found 23 grams of crack cocaine inside a duffel bag in the trunk.
- Dyson was arrested and convicted of conspiracy to possess cocaine with intent to distribute.
- On appeal, a state intermediate appellate court found “abundant probable cause” but reversed, holding the automobile exception required both probable cause and a separate showing of exigency that made obtaining a warrant impracticable.

## Issues

1. Whether the Fourth Amendment’s automobile exception requires, in addition to probable cause, a separate showing of exigent circumstances before police may conduct a warrantless search of a vehicle.

## Decision

- The Supreme Court reversed the state appellate court in a per curiam decision.
- The Court held that the automobile exception has no separate exigency requirement beyond probable cause.
- Because the state court found abundant probable cause that the vehicle contained contraband, the warrantless search was reasonable under the Fourth Amendment.

## Legal Principles

- When officers have probable cause to believe a readily mobile vehicle contains contraband or evidence of a crime, the Fourth Amendment permits a warrantless search of the vehicle.
- The automobile exception does not require an additional, case-specific finding that officers lacked time or ability to obtain a warrant.
- A vehicle search supported by probable cause is not unreasonable merely because a warrant could have been obtained.

## Conclusion

The Court held that probable cause alone satisfies the automobile exception, so a warrantless vehicle search is constitutional even absent any separate exigent circumstance preventing officers from securing a warrant.


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