California, United States of America
The following excerpt is from People v. Chavers, 189 Cal.Rptr. 169, 33 Cal.3d 462, 658 P.2d 96 (Cal. 1983):
Consequently, police officers understand that closed containers generally are covered by the warrant requirement. No confusion is caused by requiring officers to apply this same rule to a closed container wherever found, even if it happens to be located in an automobile. (But compare United States v. Ross (1982) 456 U.S. 798, 102 S.Ct. 2157, 72 L.Ed.2d 572.)
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