U.S. Second Circuit - The FindLaw 2nd Circuit Court of Appeals Opinion Summaries Blog

US v. Navas, No. 09-1144

US v. Navas, No. 09-1144, involved a drug conspiracy prosecution in which the district court suppressed narcotics seized by law enforcement officers during a warrantless search of a trailer.

As Circuit Judtge Wesley noted in the the court of appeals opinion:  "This appeal concerns a trailer, unhitched from its cab and parked in a warehouse. The district court held that a warrantless search of the trailer ran afoul of the Fourth Amendment. On appeal, defendants liken the trailer to a fixed structure, and argue that the district court properly suppressed the fruits of the search. The government argues that, whether or not attached to a cab, the trailer is subject to a warrantless search pursuant to the "automobile exception" to the Fourth Amendment's warrant requirement. As the trailer was readily mobile and commanded only a diminished expectation of privacy, we hold that the automobile exception applies."

The court of appeals reversed on the ground that the search was lawful under the "automobile exception" to the Fourth Amendment's warrant requirement.

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