California, United States of America
The following excerpt is from People v. Sims, 273 Cal.Rptr.3d 792, 59 Cal.App.5th 943 (Cal. App. 2021):
The defendant asserts the officers did not have probable cause to search his vehicle because they already had "enough information" to determine he was publicly intoxicated and "[n]o search of the car was necessary" to determine whether he was in violation of San Diego Municipal Code section 85.10. However, the automobile exception is not so narrow that it applies only when the evidence or contraband believed to be in a vehicle is non-duplicative of other evidence or strictly essential to establish a criminal offense. Rather, where officers have probable cause that a lawfully-stopped vehicle contains evidence of criminal activity or contraband, such probable cause "alone satisfies the automobile exception to the Fourth Amendment's warrant requirement ...." ( Maryland v. Dyson (1999) 527 U.S. 465, 467, 119 S.Ct. 2013, 144 L.Ed.2d 442.)
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