FindLaw > Criminal Law Summaries > 1998 Index > Maryland v. Dyson

Case: Maryland v. Dyson

Issue: Whether an exigency exception applies to searches of automobiles if there is probable cause of criminal activity.

Facts: A Maryland sheriff's deputy received a tip from a reliable informant that Defendant Kevin Dyson, a known drug dealer, was in New York purchasing cocaine and would return to Maryland in a red automobile with license plate number "DDY 787." On investigating the license plate number, the deputy confirmed that it was registered to a red automobile. On Dyson's return to Maryland, deputies searched the car and found 23 grams of cocaine base in the truck. Dyson was arrested, tried, and convicted of conspiracy to possess cocaine base with intent to distribute. Dyson successfully appealed his conviction. According to the Court of Special Appeals of Maryland, while there was abundant probable cause to search the automobile, the deputies should have secured a warrant for a search. In reversing the conviction, the court held that the deputies violated the Fourth Amendment by failing to secure a warrant because there were no exigent circumstances that prevented or rendered significantly difficult obtaining a search warrant.

Holding: In a brief, per curiam opinion, the Court reiterated its clear precedent that there is no separate exigency requirement for the search of an automobile. Law enforcement agents can search an automobile based solely on probable cause–there is no requirement that they first secure a search warrant. In holding to the contrary, the Court of Special Appeals squarely contravened binding precedent. Because there was abundant probable cause to search the automobile, Dyson's motion to suppress was properly denied.