Cop opens the passenger door and leans inside to speak to the driver. Illegal search? Ngumezi

Cop Open Door Search | Fourth Amendment Case Explained

Can a cop open a car door during a traffic stop without probable cause? The Ninth Circuit Court of Appeals made it clear: officers may not open a vehicle door and lean inside unless they have a specific, lawful justification beyond reasonable suspicion.

 

Case Background: United States v. Ngumezi

The Ninth Circuit reversed a conviction for being a felon in possession of a firearm after ruling that officers unlawfully opened the defendant’s car door during a traffic stop. The firearm found inside was suppressed as evidence.

Why the Cop Couldn’t Open the Door

The court held that while officers had reasonable suspicion to stop the car, they lacked probable cause or a specific safety justification to open the door and lean inside. This action was deemed an unlawful search under the Fourth Amendment.

Exclusionary Rule Applied

Since the gun was discovered through the unlawful search, it was considered the “fruit of the poisonous tree.” The government did not argue exceptions like attenuation or inevitable discovery, so the evidence was excluded and the conviction was vacated.

Read the Full Court Opinion

United States v. Ngumezi – Ninth Circuit Court of Appeals (PDF)

Frequently Asked Questions About Cop Opening Car Doors

Can a cop open your car door during a traffic stop?
Not without probable cause or a specific safety reason. Simply having reasonable suspicion for a stop is not enough.

What happens if police open your door unlawfully?
Evidence found may be suppressed under the exclusionary rule, as in United States v. Ngumezi.

Does officer safety justify opening the door?
Only if there is an articulable, specific concern for safety. A generalized suspicion is insufficient.

How does this ruling protect drivers?
It reinforces Fourth Amendment protections against unlawful searches and limits police intrusion without proper justification.

Contact a San Diego Criminal Defense Lawyer

Anton Vialtsin, Esq.
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