State of Louisiana v. Melvin Miguel, 263 So. 3d 873

Vehicle stop for cracked windshield revealed defendant driving with suspended license and fraudulent plate; defendant admitted recent marijuana use.
Detective scanned interior before exit and observed an orange prescription bottle with the name on its label peeled off in the broken driver-side door handle.
Defendant and passengers disclaimed ownership of the bottle.
After handcuffing and Mirandizing defendant, the detective retrieved and opened the bottle, finding five hydrocodone pills; defendant was arrested for possession.
District court denied defendant’s motion to suppress after a hearing and bodycam review; the court of appeal reversed, applying State v. Meichel and finding the plain view exception inapplicable.
Louisiana Supreme Court granted certiorari and reversed the court of appeal, holding the totality of circumstances supplied probable cause for the plain view seizure.

Issue	State's Argument	Miguel's Argument	Held
Whether seizure/search of pill bottle fit the plain view exception	Torn label plus contextual facts (suspended license, fraudulent plate, marijuana admission, disclaimers of ownership) gave probable cause to believe bottle contained contraband	Torn label alone insufficient; additional facts unrelated to bottle’s incriminating character; seizure required warrant	Yes. Totality of circumstances gave probable cause; plain view applies, suppression denied and conviction proceedings reinstated
Whether Meichel controls to require suppression	Meichel distinguishable because there were additional corroborating circumstances here	Meichel dictates suppression where officer lacked basis to know item was probably contraband when first observed	Meichel not controlling; court limits Meichel to cases lacking corroborating contextual facts

Texas v. Brown, 460 U.S. 730 (U.S. 1983) (clarifies “immediately apparent” means probable cause standard for plain view)
Horton v. California, 496 U.S. 128 (U.S. 1990) (plain view doctrine elements)
Coolidge v. New Hampshire, 403 U.S. 443 (U.S. 1971) (discusses limits of plain view language)
Brinegar v. United States, 338 U.S. 160 (U.S. 1949) (probable cause as practical, nontechnical probability)
United States v. Cortez, 449 U.S. 411 (U.S. 1981) (probabilities and common-sense in assessing suspicion/probable cause)
Carroll v. United States, 267 U.S. 132 (U.S. 1925) (articulates the reasonable-caution standard underlying probable cause)
State v. Meichel, 290 So.2d 878 (La. 1974) (plain view seizure invalid where officer lacked basis to believe pills were contraband when observed)
State v. Gray, 122 So.3d 531 (La. 2013) (summarizes plain view elements under Louisiana law)