State v. Lloyd, 312 P.3d 467

A highway patrol officer followed Lloyd into a shopping center parking lot after Lloyd ran a red light to issue a ticket.
While Lloyd stood by his car processing the ticket, a drug-detection dog was summoned and alerted to drugs in Lloyd’s car.
Without a warrant, the officer searched Lloyd’s car based on the dog’s alert and arrested Lloyd; drugs (psilocybin mushrooms and seven pounds of marijuana) were found.
Lloyd moved to suppress; the district court suppressed the search, holding that Nevada law requires exigent circumstances beyond the car’s mobility for a warrantless automobile search.
The district court recognized the dog’s alert as probable cause but found no sufficient exigency beyond mobility to justify a warrantless search.
The Nevada Supreme Court reversed, holding that exigency is not a separate requirement of the automobile exception and that probable cause plus a readily mobile vehicle justifies a warrantless search; a remand followed for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the automobile exception require a separate exigent circumstance?	Lloyd argues exigency is required under Nevada law.	State argues there is no separate exigency requirement; mobility and probable cause suffice.	No separate exigency requirement; mobility and probable cause justify search.
Does a drug-detection dog alert establish probable cause to search a vehicle?	Dog alert provides probable cause to search.	Dog alert supports probable cause; combined with mobility justifies search.	Yes; dog alert provides probable cause for a warrantless search of a readily mobile car.
Should Nevada follow federal automobile-exception framework or impose a distinct Nevada exigency rule?	Would follow federal understanding of the automobile exception.	Maintain Nevada-specific exigency requirements as precedent.	Nevada’s constitution does not require a separate Nevada exigency; aligns with federal framework.
Is a parked, immobile vehicle in a public place within the automobile exception when probable cause exists?	Probable cause plus mobility principle should apply regardless of momentary immobility.	Immobility may affect applicability under prior Nevada caselaw.	A parked vehicle may still be searched without a warrant if readily mobile and probable cause exists; focus is on mobility and probable cause.

Carroll v. United States, 267 U.S. 132 (U.S. 1925) (automobile exception grounded in probable cause and vehicle mobility)
Chambers v. Maroney, 399 U.S. 42 (U.S. 1970) (recognizes mobility as a factor in warrantless vehicle searches)
California v. Carney, 471 U.S. 386 (U.S. 1985) (lower expectation of privacy in vehicles)
Maryland v. Dyson, 527 U.S. 465 (U.S. 1999) (clarifies no separate exigency requirement for automobile exception)
Florida v. Harris, 133 S. Ct. 1050 (U.S. 2013) (dog alert can be presumptively reliable for probable cause)
Barrios-Lomeli v. State, 944 P.2d 792 (Nev. 1997) (Nevada cases on parked/mobile vehicle searches and exigency)
Harnisch v. State (Harnisch II), 954 P.2d 1180 (Nev. 1998) (Nevada held exigency required for parked immobile vehicle searches (overruled))
Harnisch v. State (Harnisch I), 931 P.2d 1359 (Nev. 1997) (earlier Nevada adoption of exigency for automobile exception)
Fletcher v. State, 990 P.2d 192 (Nev. 1999) (roadside stop consideration of automobile searches)
Barrios-Lomeli v. State, 113 Nev. 952 (Nev. 1997) (probable cause and movement status in vehicle searches)
Camacho v. State, 75 P.3d 370 (Nev. 2003) (distinctions in vehicle detentions and warrants)
Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (limits on search incident to arrest for vehicles)