Must a Vehicle Be Located in a PVA to Be Searched Without a Warrant?

In State v. Parker, __ N.C. App. __, __ S.E.2d __, 2022 WL 4850255 (Oct. 4, 2022), the Court of Appeals considered the warrantless search of a vehicle that took place at a gas station. The court upheld the legality of the search based on probable cause that the vehicle contained evidence of drug activity. In the course of its opinion, the court stated that “the automobile exception [to the warrant requirement] . . . requires that the vehicle be in a public vehicular area.” Is that right?

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Case Summaries: N.C. Court of Appeals (Feb. 16, 2021)

This post summarizes published criminal decisions from the North Carolina Court of Appeals released on February 16, 2021. Gabrielle Supak and Shea Denning prepared these summaries. As always, they will be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to present.

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Case Summaries – North Carolina Court of Appeals (July 7, 2020)

This post summarizes published criminal opinions of the Court of Appeals decided on July 7, 2020.

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