MA: Admin search doctrine or special needs didn’t permit a discretionary suspicionless search of a car on a prison parking lot

The trial court judge properly allowed defendant’s pretrial motion to suppress evidence seized during a warrantless search of his motor vehicle while it was parked in a parking lot outside a correctional facility, where, at the time a police officer instructed the defendant to unlock the vehicle to allow access to its interior, the officer lacked probable cause to believe that a prescription pill bottle visible in a map pocket on the driver’s side of the vehicle contained illegal narcotics. Further, the entry into and search of the vehicle was not justified as an administrative or special needs search, where, although correction officials have a legitimate interest in preventing the introduction of weapons, drugs, or other contraband onto the grounds of a correctional facility, in the absence of regulations or a written policy describing the parameters of an administrative search procedure or, alternatively, a procedure in which every vehicle was searched as it entered the facility, the mere posting of a sign at the entrance to the facility advising that vehicles entering the facility’s parking lot were subject to search was inadequate to justify a warrantless search conducted on a discretionary basis. Commonwealth v. Garcia-German, 2016 Mass. App. LEXIS 176 (Dec. 20, 2016). [Largely the court’s summary.]