In Maryland v. Dyson, 527 U.S. 465 (1999), sheriff's deputies, acting on a tip from a reliable confidential informant that Dyson would be driving a certain automobile containing a large quantity of cocaine, stopped and searched the vehicle, finding twenty-three grams of crack cocaine in a duffel bag in the trunk. Id. at 465-66. The trial court denied Dyson's motion to suppress the evidence, and Dyson was convicted of conspiracy to possess cocaine with intent to distribute. Id. at 466. On appeal to the Maryland Court of Special Appeals, Dyson argued that the trial court had erroneously denied his motion to suppress the cocaine on the alternative grounds that the police lacked probable cause, or that even if there was probable cause, the warrantless search violated the Fourth Amendment because there was sufficient time after the informant's tip to obtain a warrant. Id. The state appellate court reversed, holding that in order for the automobile exception to the warrant requirement to apply, there must not only be probable cause to believe that evidence of a crime is contained in the automobile, but also a separate finding of exigency precluding the police from obtaining a warrant. Id. Although the state appellate court concluded that abundant probable cause existed, it held the sheriff's deputies search violated the Fourth Amendment because there was no exigency that prevented or even made it significantly difficult for the sheriff's deputies to obtain a search warrant. Id. The United States Supreme Court granted certiorari and reversed the state appellate court's decision. Id.