United States v. Joseph Donahue

OPINION OF THE COURT

GREENBERG, Circuit Judge.

I. INTRODUCTION

In light of the “automobile exception” to the usual search warrant requirement, it is difficult to pick a worse place to conceal evidence of a crime than an automobile. The Supreme Court has interpreted — and reinterpreted — the automobile exception so expansively that the Court essentially has obviated the requirement that the government obtain a warrant to search a vehicle provided it has probable cause to believe that the vehicle contains evidence of a crime. Nevertheless, appellee Joseph Donahue made a successful challenge in the…