Maryland v. Dyson Case Brief

Maryland v. Dyson, 527 U.S. 465, 119 S.Ct. 2013 (1999)

FACTS: A deputy sheriff in St. Mary’s County received a tip from a reliable informant that Dyson, a known drug dealer, had gone to New York in a rented car to buy drugs, and would be returning that night. A description of the vehicle, including the license number, was provided. When Dyson returned in the rented car, he was stopped and the vehicle was searched without a warrant. Crack cocaine was found in a duffel bag in the trunk. Dyson sought to suppress the cocaine as it had been discovered in a warrantless search. He argued among other things that there were no exigent circumstances and the police had plenty of time to get a warrant, but that they had not done so. The Maryland court ruled that there was no exigency that prevented or even made it difficult to get a search warrant prior to the search and suppressed the evidence. The Maryland appellate court upheld that decision.

ISSUE: Is it necessary to find exigent circumstances to avoid getting a warrant for a search of a vehicle when there is probable cause that the vehicle contains contraband?

HOLDING: No

DISCUSSION: The U. S. Supreme Court rejected this argument. The Court stated that the automobile exception has no separate exigency requirement. The automobile exception is based on the “ready mobility” of the vehicle and the “reduced expectation of privacy resulting from its use as a readily mobile vehicle, “which” justified application of the vehicular exception”. California v. Carney, 105 S.Ct. 2066(1985), at 2069. Citing the more recent Pennsylvania v. Labron, 518 U.S. 938 (1996) which had a nearly identical fact pattern to this case, the Court restated the rule that “[I]f a car is readily mobile and probable cause exists to believe it contains contraband, a warrant is not needed”. There is no exigency requirement that must be met to justify a search of an automobile without a warrant.