United States v. Moore – Do It For The Caselaw

Holding: The court affirmed the district court's denial of the motion to suppress, holding that the warrantless search of the vehicle was justified by probable cause under the automobile exception.
Standard: Automobile exception to the Fourth Amendment warrant requirement
Vote: Unanimous affirmation of the district court's denial of the motion to suppress.
Practical effect: Law enforcement may conduct warrantless searches of vehicles when they have probable cause to believe evidence of a crime is inside, regardless of whether they had time to secure a warrant or whether the suspect has fled the scene.

The Sixth Circuit affirmed the denial of a motion to suppress a firearm found in a vehicle. The court held that officers had probable cause to search the car under the automobile exception to the Fourth Amendment warrant requirement.

Background

An off-duty police officer observed Jaeontae Moore brandish a firearm while arguing with a driver in a car. Officers attempted to arrest Moore, but he fled. Officers then searched the vehicle without a warrant and found a loaded pistol under the front passenger seat. Moore was indicted for being a felon in possession of a firearm and moved to suppress the evidence, arguing the search violated the Fourth Amendment.

The court’s reasoning

The court applied the automobile exception, which allows warrantless searches of vehicles on public roads if there is probable cause to believe the car contains evidence of a crime. The court found that officers had a fair probability that the firearm was in the vehicle because they saw Moore brandish it, and he fled without the weapon. The court noted that the automobile exception applies even in nonexigent circumstances, making the availability of time to obtain a warrant irrelevant. The court also held that probable cause did not evaporate when Moore fled, justifying the continued detention and search of the vehicle.

We begin with the question of probable cause and conclude that under United States v. Woods, there was probable cause to stop and search the vehicle.

United States v. Moore, No. 25-1898, slip op. at 5 (6th Cir. July 7, 2026)

What it means going forward

Law enforcement may conduct warrantless searches of vehicles when they have probable cause to believe evidence of a crime is inside, regardless of whether they had time to secure a warrant or whether the suspect has fled the scene.