SC: Automobile exception search doesn’t have to happen right away

Defendant’s car was well enough connected to him and the crime that the police had probable cause for a search under the automobile exception. Moreover, there is no constitutional requirement that the vehicle be searched immediately under the automobile exception. State v. Bonilla, 2019 S.C. App. LEXIS 191 (Dec. 31, 2019). [This has limits; e.g., the search cannot be delayed until the probable cause is stale or dissipates, but that’s not the case here.]

“Although Potts did not explicitly argue that the traffic stop was pretextual below, the Superior Court correctly noted that an officer’s subjective intentions play no role in a Fourth Amendment analysis.” Potts v. State, 2019 Del. LEXIS 566 (Dec. 30, 2019).*

Playpen warrant sustained. Discovery into details that could compromise future operations was properly denied. United States v. Stamper, 2019 U.S. App. LEXIS 38711 (6th Cir. Dec. 30, 2019).*