Is there any reason to deny a suppression motion concerning the physical evidence discovered in a search of a car found by a search warrant?

Atkins makes only the barest of challenges to the district court's denial of her suppression motion concerning the physical evidence discovered in the car. Atkins apparently contends that because her arrest was not supported by probable cause, the evidence discovered in the ensuing search of the car was invalid. First, the arrest was valid, as discussed above. Moreover, the propriety of the arrest would not be directly relevant even if the arrest had been invalid; the government does not argue that the search of the car was valid as incident to a lawful arrest. Nor could it. See, e.g., Chambers v. Maroney, 399 U.S. 42, 47 (1970) ("Once an accused is under arrest and in custody, then a search made at another place, without a warrant, is simply not incident to the arrest.").

We find that the search of the car was proper because it was supported by probable cause to believe that the vehicle contained evidence of criminal activity. See generally, United States v. Ross, 456 U.S. 798 (1982). Probable cause for this belief arose from these facts: 1) the vehicle's license plate number matched that of a suspected getaway car from a bank robbery approximately ten days previously; 2) the vehicle was a large, American car, matching several eyewitness descriptions of the getaway car in several recent bank robberies in the area; and 3) a woman discovered inside the car matched "remarkably clear" surveillance photos taken during three different bank robberies. Although the second piece of information has little probative value, the first and third taken together provide the requisite probable cause to believe that a search of the contents of the car would provide evidence related to the bank robberies.