In September 2023, emergency responders received a report from a woman stating that her mother's boyfriend, identified as Stephen Woods, had assaulted her and threatened her with a gun. Dispatchers sent Officer Overly to the apartment complex with descriptions of Woods as an armed suspect driving an orange Dodge. Upon arrival, Officer Overly spoke with the victim and her daughter, who confirmed that Woods had slapped the victim, kicked her, and held a small gun to her chest. Overly observed a man matching the description fleeing into the building and radioed that he was running through the complex. After a canine search and a visual sweep of the parking lot failed to locate Woods or the weapon, Officer Blank discovered Woods in his orange Dodge. When Blank attempted to detain him, Woods resisted until another officer arrived. A pat-down of Woods yielded no weapon, and a visual inspection of the car's interior revealed nothing. Using the keys provided by Woods, officers unlocked the vehicle and discovered a pistol under the front passenger seat. Woods was subsequently charged with possession of a firearm as a felon. He moved to suppress the gun, arguing the warrantless search violated the Fourth Amendment, but the district court denied the motion. Woods pleaded guilty while reserving the right to appeal the suppression ruling.
The Sixth Circuit, in an opinion by Judge Thapar, focused on whether the officers possessed probable cause to search the vehicle under the automobile exception to the warrant requirement. The court reiterated that probable cause is not a high bar, requiring only a 'fair probability' that evidence of a crime will be found in a specific location, rather than a certainty or the elimination of all other possibilities. The court found that the officers reasonably believed the gun was evidence of a crime based on two eyewitness accounts confirming Woods had threatened the victim with a firearm. The critical legal analysis turned on the location of the gun. The officers knew the gun was last seen in Woods's possession but had not found it on his person, near the victim, or in the parking lots after a canine search. The court reasoned that because the gun was not found elsewhere, there was a fair probability it had been stashed in the car where the suspect was detained. The court explicitly rejected the defendant's argument that officers must eliminate all alternative locations for the evidence before searching a vehicle. Citing United States v. White, the court clarified that while eliminating alternatives strengthens probable cause, it is not a requirement. The court also distinguished cases where probable cause was lacking, noting that in those instances, suspects were not detained at or near their vehicles, whereas here, the suspect was found immediately after exiting his car. The court concluded that a reasonable officer would consider it likely the gun was in the vehicle given the circumstances.
The decision reinforces the scope of the automobile exception, clarifying that law enforcement does not need to exhaust all other search possibilities or eliminate every alternative location for evidence before searching a vehicle. It establishes that when a suspect is detained at their vehicle and a weapon described by witnesses is not found on the person or in the immediate vicinity, probable cause exists to search the vehicle. The case is remanded to the district court for sentencing, though the defendant had already pleaded guilty. The ruling leaves open the question of whether the standard changes if the suspect is not detained at the vehicle or if the evidence is not described as being in the suspect's immediate possession.
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