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United States v. King
Citation: 18 F. App'x 480Docket: No. 00-30381; D.C. No. CR-99-00106-JKS
Court: Court of Appeals for the Ninth Circuit; August 24, 2001; Federal Appellate Court
Robert Lee King entered a conditional guilty plea for possession of over five grams of crack cocaine, while reserving the right to appeal the district court’s denial of his motion to suppress evidence from a warrantless search. The district court determined that the search was lawful as it was incident to King's arrest, which was deemed reasonable. King's main argument was that officers lacked probable cause for the search. However, the court found that, based on the totality of the circumstances—including the presence of cash and a digital scale with white powder in the vehicle's center console—experienced officers could reasonably conclude that King was involved in drug dealing. The court referenced several precedents supporting the notion that a stop in a high-crime area is a significant factor for establishing probable cause. It upheld that officers had the authority to conduct a reasonable search incident to King’s arrest, regardless of whether the search occurred just before or after the formal arrest. King also argued that the search exceeded reasonable bounds. However, the court concluded that the officers' search was not extreme or abusive, as they were aware that suspects may conceal drugs in their groin area. The court cited case law indicating that a typical pat-down includes thorough searches of sensitive areas, and once drugs were detected, officers were justified in removing them. Ultimately, the district court's denial of King's suppression motion was affirmed, and the decision is not intended for publication or citation in future cases, as per Ninth Circuit Rule 36-3.