State v. Meeks

This case involves the important and difficult question of protecting citizens from constitutionally prohibited searches, on the one hand, and providing proper protection to arresting police officers, on the other. I have concluded to concur only in the result reached in the principal opinion for the reasons which follow.

At the outset, it is clear that the state does not seek to and cannot justify the search in this case on the ground that the officer had probable cause to believe the vehicle contained articles he was entitled to seize; hence cases such as Chambers v. Maroney, 399 U.S. 42, 90…