People v. Dumas

In People v. Dumas (1973) 9 Cal.3d 871, officers obtained a warrant to search defendant's apartment. The warrant did not include defendant's car or any other vehicle. (Ibid.) A search of the apartment revealed no contraband, but the officers found a car registration certificate for a car parked on the street. The officers searched the car and found narcotics. (Ibid.) The California Supreme Court held that exigent circumstances justified the search: the officers did not know about the car at the time they obtained the warrant and someone in defendant's apartment could have moved the car or destroyed the evidence if an immediate search was not conducted. ( Id. at pp. 884-885.) The court also held that probable cause existed to search the car because it was likely that defendant had the contraband the officers were seeking, and the contraband was likely to be in the car as it was not in the apartment.