Criminal Practice – Search & Seizure – Warrantless Search – Parked Car – Drug Transactions – K-9 Alert

Even though the warrant to search defendant’s house and person did not encompass a car parked across the street from the house, officers had probable cause to search the car, which was parked on a public road, based on controlled purchases by a confidential information, the officers’ observation of defendant and the CI at the trunk of the car during a controlled purchase, and a K-9 officer’s alert after an open-air sniff.

We affirm the trial court’s denial of defendant’s motion to suppress.

State v. Degraphenreed (Lawyers Weekly No. 011-274-18, 19 pp.) (John Tyson, J.) Appealed from Forsyth County Superior Court (Susan Bray, J.) John Payne for the state; Allegra Collins for defendant. N.C. App.