LA1: Subjective beliefs of officer irrelevant when PC exists

The trial court is reversed. There was probable cause for defendant’s stop. “Under the law, ‘the subjective beliefs or expectations of the detaining officer’ are irrelevant.” State v. Lee, 2021 La. App. LEXIS 1840 (La. App. 1 Cir. Dec. 6, 2021).

There was probable cause for seizure and search of defendant’s vehicle, and then a search warrant was obtained because it was locked. “For Fourth Amendment purposes, once that probable cause exists there is ‘no difference’ between that warrantless vehicle search and what the officers did here—‘seizing and holding a car before presenting the probable cause issue to a magistrate.’ See Chambers v. Maroney, 399 U.S. 42, 51-52 (1970).” United States v. Penny, 2021 U.S. App. LEXIS 36003 (5th Cir. Dec. 7, 2021).*