State v. Bliss, 390 P.3d 1099

Trooper stopped defendant for speeding (79 mph in 60 zone); officer smelled marijuana and ran plates that did not match the vehicle.
During the stop officer pat‑frisked defendant for weapons and felt a glass pipe; defendant admitted it was a meth pipe and officer found meth residue on defendant.
Officer then searched the vehicle without a warrant, found two large bags of marijuana in a backpack and additional white powder.
Defendant was charged with delivery of marijuana and meth possession counts; trial court denied defendant’s motion to suppress the vehicle evidence, the patdown evidence, and his admission; state later dismissed meth counts and defendant was convicted on delivery of marijuana after stipulated evidence.
On appeal defendant argued the Oregon automobile exception (from State v. Brown) does not authorize a warrantless search when a moving vehicle was stopped for a traffic violation rather than for suspected criminal activity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Oregon’s automobile exception authorizes a warrantless search when officers lawfully stop a moving vehicle for a traffic violation and, during the stop, develop probable cause to search	State: Brown’s automobile exception permits a warrantless search whenever a lawfully stopped vehicle was mobile at time of stop and officer develops probable cause, regardless of whether the stop was for a traffic offense or crime	Defendant: Brown and later cases limit the exception to situations where police encounter the vehicle in connection with a suspected crime, so a stop for a traffic violation does not trigger the exception	Held: The automobile exception applies to any lawful roadside stop of a moving vehicle (traffic stop or criminal stop) if officer develops probable cause to search
Whether admission and meth evidence require suppression or were harmless given marijuana conviction	State: Any error admitting meth evidence was harmless because conviction was only for marijuana delivery	Defendant: Admission/evidence should be suppressed and could have affected the outcome	Held: Any error was harmless; conviction for marijuana delivery stands

State v. Brown, 301 Or 268 (establishing Oregon automobile exception permitting warrantless search of a lawfully stopped, mobile vehicle when probable cause exists)
State v. Kock, 302 Or 29 (holding automobile exception does not apply to parked, immobile, unoccupied vehicles encountered in connection with a crime)
State v. Meharry, 342 Or 173 (examining when vehicle was first encountered "in connection with a crime" for automobile exception analysis)
State v. Kurokawa-Lasciak, 351 Or 179 (discussing scope of Brown and when automobile exception applies relative to encounter in connection with crime)
State v. Watson, 353 Or 768 (noting—in dicta—that Brown allows warrantless searches following a lawful traffic stop when probable cause develops)
State v. Andersen, 269 Or App 705 (Or App) (analyzing pre‑Brown law and clarifying that Brown’s exception applies to vehicles lawfully stopped while moving)