State of Washington v. Cory Wayne Roberts, 33887-8

Roberts was a passenger in a car stopped for speeding; he voluntarily gave an expired license and said he received the car from a friend but had no documentation.
Dispatch confirmed the driver lacked a valid license and Roberts’s license was suspended; officer called the registered owner, who told the officer Roberts had the right to be in the vehicle but could not produce title/registration.
Officer cited the driver, told both men they could not drive and would need to call someone; the driver then signed Ferrier warnings and consented to a vehicle search; Roberts did not object (disputed whether he explicitly consented).
During the search officer found a jacket behind the driver’s seat with a glass pipe in a pocket; Roberts said the jacket was his and, after Miranda warnings, said he found the pipe while cutting wood; residue tested positive for methamphetamine.
Roberts was charged with possession of methamphetamine and use of drug paraphernalia, moved to suppress the pipe and his statement; trial court denied suppression, convicted him, and appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge search	State: Roberts lacked standing because he did not own the vehicle	Roberts: Owned the jacket and had constructive possession, so automatic standing for possessory offense	Court: Roberts had automatic standing under Washington rule and could challenge the search
Consent vitiated by illegal detention	State: Consensual search valid because men were told they could not drive and therefore free to leave	Roberts: Detention was unlawful and vitiated consent	Court: Circumstances amounted to freedom to leave; not illegally detained; consent search valid
Admission of statement about jacket ownership (Miranda)	State: Question was not custodial interrogation requiring Miranda	Roberts: Question was custodial and his statement should be suppressed	Court: Under totality, not custodial; Miranda not required; statement admissible
Sufficiency and chain-of-custody challenges	State: Evidence proved substance and possession; chain properly established	Roberts: Evidence/pipe differed and chain broken	Court: Evidence sufficient; no error on chain of custody

State v. Ferrier, 136 Wn.2d 103 (1998) (police must advise of right to refuse or limit consent to search for vehicle owners/operators)
State v. Jones, 146 Wn.2d 328 (2002) (automatic standing for possessory offenses)
State v. Simpson, 95 Wn.2d 170 (1980) (standing and possession principles)
State v. Blazina, 182 Wn.2d 827 (2015) (addressing LFOs and related procedural matters)
State v. Heritage, 152 Wn.2d 210 (2004) (Miranda required only for custodial interrogation)
State v. Wilkinson, 56 Wn. App. 812 (1990) (frisk during traffic stop does not convert stop into arrest)
State v. Bradshaw, 152 Wn.2d 528 (2004) (elements required to prove unlawful possession of a controlled substance)
State v. McFarland, 127 Wn.2d 322 (1995) (limitations on raising unsubstantiated trial-fairness claims on direct appeal)