United States v. Jose Ochoa-Lopez, 31 F.4th 1024

FBI investigated suspected dealer Tervarie Lottie for months: multiple controlled buys, physical surveillance, and court-authorized wire/electronic intercepts.
Intercepts showed Lottie arranging a half-kilogram heroin buy from a supplier who had a significant leg injury and would arrive in Rockford to "run a test."
On the transaction day, agents observed Lottie visit locations where he stored drugs and cash, then go to an address he texted the supplier; shortly after, a white Toyota Corolla stopped at Lottie’s residence for 10–15 minutes and then left.
Officers stopped the Corolla for traffic violations, observed the passenger’s leg injury (and a walker in the trunk), and rejected the drivers’ story that they were merely transporting the car for a company.
A warrantless search of the Corolla uncovered a Louis Vuitton backpack containing over $47,000 in cash; the district court denied a suppression motion, and Ochoa-Lopez preserved the issue on appeal.
The Seventh Circuit affirmed, holding that under the totality of circumstances the agents had probable cause to search the vehicle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether agents had probable cause to conduct a warrantless search of the vehicle	Ochoa-Lopez: No probable cause—discrepancies (different address, crutches vs. walker, out-of-state plate) and mere proximity to suspected drug activity insufficient	Government: Totality of circumstances established a fair probability of contraband — intercepted calls, surveillance of Lottie collecting drugs/cash, timing/location, passenger’s leg injury matching supplier, and driver’s false story	Court: Affirmed — probable cause existed under the automobile exception; search constitutional

Arizona v. Gant, 556 U.S. 332 (2009) (warrantless searches are per se unreasonable except for established exceptions such as the automobile exception)
Katz v. United States, 389 U.S. 347 (1967) (framework for Fourth Amendment privacy protections)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause)
United States v. Sands, 815 F.3d 1057 (7th Cir. 2015) (probable cause exists when there is a fair probability contraband will be found)
United States v. Kizart, 967 F.3d 693 (7th Cir. 2020) (discussing automobile-exception standards)
United States v. Ingrao, 897 F.2d 860 (7th Cir. 1990) (presence near suspected activity insufficient alone for reasonable suspicion/probable cause)
United States v. Bohman, 683 F.3d 861 (7th Cir. 2012) (similarly limiting weight of mere departure from a suspected drug location)