People v. Koehn

In People v. Koehn (1972) 25 Cal.App.3d 799, after defendant was arrested for carrying a concealed weapon, which could be seen through the windshield of the car, the officer made a comprehensive search of the vehicle. He pried open a locked tire well with a crowbar and found narcotics. The conviction was reversed because the search was unreasonably expansive in the light of the circumstances at the time the vehicle was stopped.