Maryland v. Dyson

527 U.S. 465 (1999)

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Nature of the Case

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Facts

Acting on a tip from a confidential and reliable informant and a subsequent investigation, sheriff's deputies stopped and searched D's automobile. The tipster said that D had gone to New York to buy drugs, and would be returning to Maryland in a rented red Toyota, license number DDY 787, later that day with a large quantity of cocaine. As for the investigation, the police found that the license number belonged to a red Toyota Corolla that had been rented to D who was a known drug dealer in St. Mary's County. They found 23 grams of crack cocaine in a duffel bag in the trunk. D was convicted of conspiracy to possess cocaine with intent to distribute. In reversing, the Maryland Court of Special Appeals held that in order for the automobile exception to the warrant requirement under the Fourth Amendment to apply, there must be not only probable cause to believe that evidence of a crime is contained in the automobile, but also a separate finding of an exigency which precluded the police from obtaining a warrant. Although there was abundant probable cause, the court concluded that the search violated the Fourth Amendment because there was no exigency that prevented or even made it significantly difficult for the police to obtain a search warrant. The Maryland Court of Appeals denied certiorari. The Supreme Court grant certiorari.