State of Maryland v. Johnson, 183 A.3d 119

Officer Sheehan (12‑year veteran, drug‑interdiction training) stopped Ms. Johnson’s car for a defective brake light in a high‑crime area; dashcam recorded the encounter.
Officer observed simultaneous furtive movements by driver (reaching toward center console) and front‑seat passenger (lifting and reaching toward floorboard); both appeared unusually nervous and gave evasive answers.
Officers ran records: both passengers had prior drug‑distribution convictions. A canine unit arrived; occupants were ordered out. The front passenger (Haqq) consented to a search and had 13.14 g marijuana on his person and PCP odor on his breath; he was arrested.
Officers searched the passenger compartment (found nothing) and then searched the trunk, finding ~104.72 g marijuana and paraphernalia; Johnson was arrested.
The suppression court denied motions to suppress (found reasonable suspicion to extend the stop and probable cause to search the trunk). The Court of Special Appeals reversed as to the trunk search; Maryland Court of Appeals granted certiorari and reversed the intermediate court, holding probable cause supported the trunk search.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Johnson)	Held
Whether officers had probable cause to search the trunk under the automobile exception	Totality (furtive movements, extreme nervousness, high‑crime area, passengers’ drug priors, dog reaction, marijuana and PCP on passenger) gave fair probability more contraband was in the vehicle, authorizing search of trunk	Evidence of drugs on passenger alone did not establish nexus to trunk; search should be limited to areas passenger could access (passenger compartment); nervousness alone insufficient	Yes — court held probable cause existed to search the trunk based on totality of circumstances; reversed Court of Special Appeals

Carroll v. United States, 267 U.S. 132 (establishing automobile exception to warrant requirement)
United States v. Ross, 456 U.S. 798 (scope of automobile search defined by object and places where it may be found)
California v. Acevedo, 500 U.S. 565 (probable cause to search a container within a vehicle limits scope to that container)
Wyoming v. Houghton, 526 U.S. 295 (officers with probable cause to search vehicle may inspect passengers’ belongings capable of concealing contraband)
Ornelas v. United States, 517 U.S. 690 (appellate review standards for probable cause; give due weight to officer credibility)
Illinois v. Gates, 462 U.S. 213 (totality‑of‑circumstances test for probable cause)
United States v. Arvizu, 534 U.S. 266 (look to cumulative facts; avoid divide‑and‑conquer analysis)
Maryland v. Pringle, 540 U.S. 366 (inference of common enterprise among vehicle occupants can support probable cause)