People v. Johnson, 21 Cal. App. 5th 1026

Surveillance camera recorded Johnson engage in a hand-to-hand exchange: he produced a knotted plastic bag with multiple off‑white rock‑like solids, handed one to a woman who gave him $5.
Officers identified the car and license plate; Johnson drove away, later returned and was arrested about two blocks from where the transaction occurred.
On arrest officers found Johnson's keys but no money or drugs on his person; they went to the parked car where a woman sat in the driver seat.
An officer observed a small bag of what appeared to be marijuana on the front passenger seat (plain view); the officer smelled marijuana and, after the woman exited, searched the car and found a bag of off‑white solids (cocaine base), a $5 bill, and an EBT card in Johnson’s name.
Johnson moved to suppress the evidence from the warrantless automobile search; the trial court denied the motion, finding (1) the search was valid incident to arrest under Arizona v. Gant and (2) plain‑view observation of marijuana plus recent driving supported probable cause for transportation for sale.
Johnson pleaded no contest to sale of cocaine base and admitted related gang and prior‑strike allegations; he appealed the denial of the suppression motion. The Court of Appeal affirmed.

Issue	Johnson's Argument	People/AG's Argument	Held
Was the search of Johnson's car valid as a search incident to arrest under Gant?	Search invalid because the car was located two blocks from where Johnson was arrested, so he lacked contemporaneous access.	Search valid under Gant because officers reasonably believed the car contained evidence of the arrest offense.	Search incident to arrest under Gant was not valid: the search did not occur “when and where” Johnson was arrested, so Gant’s second prong (belief vehicle contains evidence of the crime) did not justify this search as incident to arrest.
Was the warrantless automobile search justified by probable cause (automobile exception/Ross)?	Observation of an unspecified small amount of marijuana in the car did not necessarily establish probable cause because medical use and decriminalization can make small‑amount possession lawful.	Probable cause existed: surveillance showed Johnson had remaining off‑white rocks and money, he entered the car immediately after the sale, and officers reasonably believed the car contained the remaining contraband and proceeds.	The search was supported by probable cause under the automobile exception: totality of circumstances made it reasonably probable contraband/evidence (remaining rocks, money) were in the car, so suppression was properly denied.

Arizona v. Gant, 556 U.S. 332 (recognizes two Gant prongs for vehicle search incident to arrest)
New York v. Belton, 453 U.S. 454 (permitted vehicle passenger‑compartment searches incident to lawful custodial arrest)
Chimel v. California, 395 U.S. 752 (search incident to arrest limited to arrestee and area within immediate control)
United States v. Ross, 456 U.S. 798 (automobile exception permits warrantless search of areas where evidence might be found when probable cause exists)
Thornton v. United States, 541 U.S. 615 (addressed Belton scope and led to Justice Scalia’s concurrence suggesting evidence‑based limitation)
Pennsylvania v. Labron, 518 U.S. 938 (automobile exception applies to readily mobile vehicles when probable cause exists)
Davis v. United States, 564 U.S. 229 (discusses Gant’s two‑part rule and limits of Belton)