ID: Def’s purse was in car at time of dog alert, so it was subject to search under automobile exception

Defendant’s purse was in her vehicle when a dog alerted on it. By the time the police were going to search her car, the purse was in her hands. The purse could be searched under the automobile exception because it was in the car at the time of the dog sniff when probable cause developed. State v. Easterday, 2015 Ida. App. LEXIS 57 (July 6, 2015):

However, under the automobile exception, there are no special containers, and it is immaterial where the container is located within the vehicle or whether the occupant exited the vehicle with the container. Ross, 456 U.S. at 825; Smith, 152 Idaho at 121, 266 P.3d at 1226. While a purse is a personal item akin to a billfold, precedent applying the automobile exception provides for search of all containers with the sole exception of the person, including their clothing. Accordingly, the district court did not err in concluding that the automobile exception to the warrant requirement justified the search of Easterday’s purse following the dog’s alert on the vehicle.