Sunday, November 17, 2013

United States v. Brown case brief

United States v. Brown case brief summary
203 Fed.Appx. 997 (2006)

Defendant appealed his conviction for violating 21 U.S.C.S. §§ 963 and 846. He asserted that the United States District Court for the Southern District of Florida erred in denying his motion to suppress evidence seized from his girlfriend's car because they lacked probable cause to search the car and that the police exceeded the scope of a valid inventory search warrant when they read the contents of a document found in the car.


  • The government did not challenge defendant's standing to challenge the search of his girlfriend's car. 
  • Based on the totality of the evidence known at the time, the authorities had a reasonable belief that defendant used the car to facilitate the drug transaction and a reasonable belief that they would find drugs or other evidence of criminal activity inside the car. 
  • Thus, the authorities had probable cause to search the car, and the search was permissible under the automobile exception to the Fourth Amendment's warrant requirement. 
  • The appellate court did not address whether authorities exceeded the scope of a valid inventory search by reading the contents of the seized documents because the warrantless search of the car was otherwise supported by probable cause, and thus, the district court did not err in denying defendant's motion to suppress.

Defendant's conviction was affirmed.

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