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Cardwell v. Lewis


Officers went to the defendant’s place of business to question him in connection with a murder investigation. While there, the officers saw the car they suspected might have been used in the murder. Several months later, the officers questioned the defendant again. They also obtained an arrest warrant. The defendant drove his car to the station for questioning and left his car in a commercial parking lot. The suspect was arrested and the car was towed to a police impound lot where a warrantless examination of its exterior was conducted the following day.


Whether the examination of an automobile’s exterior is reasonable under the Fourth Amendment?


Yes. The defendant had no reasonable expectation of privacy in the exterior of his automobile.


Nothing from the interior of the car and no personal effects were searched or seized. The intrusion was limited to the exterior of the vehicle left in a public parking lot. No reasonable expectation of privacy is violated by the examination of an exposed tire or in the taking of exterior paint samples from a vehicle that had been parked in a public place. Further, the officers had probable cause to search the car. Where probable cause exists, a warrantless search of an auto is reasonable under the Fourth Amendment. See Carroll v. United States.


417 U.S. 583, 94 S. Ct. 2464 (1974)

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