Taylor v. State, 137 A.3d 1029

Taylor was stopped for traffic violations at ~1:00 a.m.; officer detected odor of alcohol, slurred speech, bloodshot eyes; Taylor failed field sobriety tests and was arrested for DUI.
After arrest, backup officer searched Taylor’s car and found cocaine in the front center armrest; Taylor was prosecuted for possession with intent to distribute and DUI.
Taylor moved to suppress the cocaine, arguing the vehicle search violated the Fourth Amendment under Arizona v. Gant because he was secured and had no access to the vehicle.
The trial court denied suppression; the Court of Special Appeals affirmed; this appeal addressed only the suppression issue (no material factual disputes; legal issue governed the outcome).
The central question was whether, under Gant, an arrest for DUI permits a search of the passenger compartment when the arrestee is secured, based on the officer’s belief that evidence related to the DUI (e.g., open containers) might be in the vehicle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a vehicle search incident to arrest is lawful under Gant when the arrestee is secured and has no access to the car	Taylor: Gant requires independent reasonable articulable suspicion that evidence of the offense is in the vehicle; nature of the offense alone cannot supply a per se right to search	State: Under Gant, it is "reasonable to believe" evidence relevant to a DUI may be in the passenger compartment; officer experience and knowledge can supply the needed basis	Court: "Reasonable to believe" is equivalent to reasonable articulable suspicion; officer’s training/experience that DUI stops often involve open containers provided a sufficient, articulable basis for the search; suppression denied

Arizona v. Gant, 556 U.S. 332 (2009) (limits vehicle searches incident to arrest; permits search when arrestee unsecured/within reach or when it is reasonable to believe vehicle contains evidence of the offense)
Chimel v. California, 395 U.S. 752 (1969) (search-incident-to-arrest limited to arrestee and area within immediate control)
New York v. Belton, 453 U.S. 454 (1981) (permitted searching passenger compartment as contemporaneous incident to arrest of occupant)
Katz v. United States, 389 U.S. 347 (1967) (warrantless searches presumptively unreasonable absent exceptions)
Thornton v. United States, 541 U.S. 615 (2004) (concurrence recognizing vehicle-context circumstances may justify searches incident to arrest)
United States v. Cortez, 449 U.S. 411 (1981) (reasonable suspicion assessed through the prism of experienced law enforcement)
United States v. Washington, 670 F.3d 1321 (D.C. Cir. 2012) (upheld vehicle search after DUI arrest under Gant where evidence of intoxication made search reasonable)