Suppression of Evidence

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7^th Circuit Court of Appeals

Case Name: United States of America v. Charles Hays

Case No.: 22-3294

Officials: Flaum, Scudder, and Kirsch, Circuit Judges.

Focus: Suppression of Evidence

This concerns a Fourth Amendment matter revolving around the warrantless search of a vehicle. Hays, the defendant, was pulled over by the police while driving, and his passenger was discovered with methamphetamines. Subsequently, the police officers searched the interior of the vehicle but found no drugs. However, during an inspection under the car’s hood, within the air filter, they uncovered additional methamphetamines.

Hays was charged, and later he sought to suppress the evidence gathered during the traffic stop, contending that the officers lacked probable cause to search under the hood and in the air filter. The district court rejected his motion, leading Hays to enter a guilty plea for possession with intent to distribute 50 grams or more of methamphetamines while preserving his right to appeal the denial of his motion to suppress.

The Seventh Circuit upheld the district court’s decision, asserting that, in accordance with the automobile exception to the Fourth Amendment’s warrant requirement, officers can conduct a warrantless search of a vehicle, including all parts where there is a reasonable likelihood that contraband could be concealed, provided there is probable cause to believe it harbors contraband or evidence of illegal activity. The court determined that, considering the overall circumstances, such as the passenger’s possession of methamphetamines, Hays’s prior drug-related arrest, and the presence of a screwdriver in the car—an implement known for hiding drugs in vehicles—officers had a reasonable basis to believe that methamphetamines could be concealed in the car, including under its hood.

Affirmed.

Decided 01/12/24

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