In People v. Dalton (1979) 24 Cal.3d 850, the court said a warrantless search of closed containers found within an automobile involves considerations separate from those involved in a warrantless search of the interior of the automobile, and "it must be justified by some recognized exceptions to the warrant requirement." ( People v. Dalton, supra , 24 Cal.3d at p. 856.) Further, the court emphasized that individuals have a greater privacy interest in the contents of closed luggage than in the interior of an automobile. It went on to note that luggage is easier to secure while seeking to obtain a warrant than is an automobile. Therefore, the court concluded that for closed containers, found within an automobile or elsewhere, the requirements of exigency and probable cause to open the container must be established to justify a warrantless search of the containers. The court did not find a lack of emergent necessity for a warrantless search of the trunk of the car. As pointed out, the court had prefaced this discussion by emphasizing the greater privacy interest in luggage which distinguished it from the interior of the automobile. The Dalton court specifically said at page 857: "Further, the fact that the boxes were found in the trunk of an automobile after the officers legitimately opened the car's trunk cannot validate their later being searched."