California, United States of America
The following excerpt is from People v. Ruggles, 138 Cal.App.3d 950, 188 Cal.Rptr. 401 (Cal. App. 1983):
"Whether exigent circumstances existed under Arkansas v. Sanders (1979) 442 U.S. 753, 99 S.Ct. 2586, 61 L.Ed.2d 235, to justify the warrantless search of an unlocked briefcase found in suspect's car trunk where the suspect was arrested in his car at the center divider of a freeway and the arresting officers had probable cause to believe that a firearm to be used in a robbery was secreted in the briefcase.
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