California, United States of America
The following excerpt is from People v. Superior Court for Alameda County, 141 Cal.Rptr. 562, 74 Cal.App.3d 488 (Cal. App. 1977):
Wimberly v. Superior Court, supra, suggests that under certain circumstances it may be necessary to secure a warrant to search the trunk of a car. (See 16 Cal.3d at pp. 566-573, 128 Cal.Rptr. 641, 547 P.2d 417.) The rule distilled from the cases reviewed by the court in that opinion is: "(T)he existence of probable cause to search the interior of a car is not necessarily sufficient to justify the search of the car's trunk. A search based on probable cause which reasonably only tends to support the inference that contraband or evidence will be found in the passenger compartment will be of intolerable intensity and scope if expanded to include a closed trunk. In such a situation there must be some specific articulable facts which give reasonable cause to believe that seizable items are, in fact, concealed in the trunk." (16 Cal.3d at p. 568, 128 Cal.Rptr. at p. 648, 547 P.2d at p. 424.)
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