311 Conn. 626
Conn.2014Background
- On March 25, 2010 Waterbury officers in plainclothes observed a suspected street-level drug transaction involving Williams’s parked vehicle; an outside participant dropped a small bag of suspected cocaine.
- Officers smelled strong unburnt marijuana from the vehicle, ordered occupants out, handcuffed Williams after he reached toward the center console, and found apparent cocaine in the console and marijuana on the passenger floor.
- While inspecting the rear seat (which folded into the trunk), officers saw a dark plastic bag that smelled of marijuana, opened it, found drugs and a second opaque black bag that contained a handgun.
- Williams moved to suppress the trunk/container seizures; the trial court denied the motion. He pleaded nolo contendere conditionally and appealed, asking this Court to reconsider Connecticut precedent allowing warrantless searches of closed containers in trunks under the automobile exception to article first, § 7.
- The Court conducted a Geisler analysis and reaffirmed prior Connecticut cases holding that, under article first, § 7, probable cause to search an automobile justifies searching containers within it without a warrant in on-the-scene automobile searches.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether article first, § 7 prohibits warrantless search of a closed container in a vehicle trunk during an otherwise lawful on‑the‑scene automobile search | State: prior Connecticut precedent allows searches of containers in vehicles when there is probable cause to search the vehicle | Williams: state constitution should afford greater protection than the Fourth Amendment; police must get a warrant to search a closed container absent exigent circumstances | Court: affirmed Dukes/Longo — probable cause for vehicle permits search of containers in it; decline to add an exigency requirement under state constitution |
Key Cases Cited
- United States v. Ross, 456 U.S. 798 (U.S. 1982) (establishes that probable cause to search a vehicle permits searching containers within it)
- California v. Acevedo, 500 U.S. 565 (U.S. 1991) (permits search of an automobile and containers within it when probable cause exists)
- State v. Dukes, 209 Conn. 98 (Conn. 1988) (recognized automobile exception under Connecticut constitution)
- State v. Longo, 243 Conn. 732 (Conn. 1998) (held that probable cause to search vehicle permits searching containers found in vehicle)
- State v. Miller, 227 Conn. 363 (Conn. 1993) (distinguishes post‑impound searches and explains limits where automobile exception no longer justified)