State v. Bliss, 423 P.3d 53

Officer stopped Bliss for speeding; vehicle was mobile and stop was lawful.
Officer smelled marijuana, noted defendant's nervousness, parole status, and repeated reaching under the seat.
Officer patted down Bliss, discovered a meth pipe and other suspected meth residue, and arrested him.
Officer searched the vehicle without a warrant and found marijuana and drug paraphernalia; evidence used to convict Bliss of delivery of marijuana.
Bliss moved to suppress-person and vehicle searches and his admission about the pipe—arguing the automobile exception did not apply because the initial stop was for a traffic infraction and probable cause arose only during the stop.
Trial court and Court of Appeals denied suppression; Oregon Supreme Court affirmed, holding Brown’s automobile exception applies when (1) the car was mobile when lawfully stopped and (2) probable cause existed at time of the search.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bliss)	Held
Whether the automobile exception permits a warrantless search of a vehicle stopped for a traffic infraction when probable cause to search develops during the stop	Automobile exception applies so long as vehicle was mobile when lawfully stopped and police had probable cause at time of search	Automobile exception should be limited to stops that are "in connection with a crime"—i.e., officers must have probable cause to search at the time they initiate the stop; traffic stops are insufficient	Held for State: automobile exception applies if car was mobile at lawful stop and officers had probable cause at time of search; no warrant required

State v. Brown, 301 Or. 268 (Oregon 1986) (announcing automobile exception: mobile vehicle + probable cause justifies warrantless search)
State v. Kock, 302 Or. 29 (Oregon 1986) (automobile exception does not cover parked, immobile, unoccupied vehicles)
State v. Meharry, 342 Or. 173 (Oregon 2006) (vehicle considered encountered and mobile when observed driving into parking lot)
State v. Kurokawa-Lasciak, 351 Or. 179 (Oregon 2011) (automobile exception inapplicable to parked, immobile, unoccupied vehicles encountered in criminal investigation)
State v. Watson, 353 Or. 768 (Oregon 2013) (describing automobile exception: officer who has stopped a mobile vehicle may search without warrant if probable cause exists)
State v. Andersen, 361 Or. 187 (Oregon 2017) (reaffirming mobility requirement; radio/communications can establish encounter with mobile vehicle)