State V. Rounds Case Summary

In the case of State v. Rounds, the defense challenges the conduct of Officer Oliver Towns and the evidence his conduct yielded. The defense wages their action on three major cases, all of which apply, but none in the way cited: Riley V. California, 573 U.S. ____ (2014), Wong Sun v. United States, 371 U.S. 471, (1963) and Carroll v United States, 267 U.S. 132 (1925). This case can be narrowed down to three stages: the stop, the search and the seizure. All of which, when performed, obeyed the limits and stipulations set by the Fourth Amendment and precedent. The initial stop of Rounds was entirely valid because Rounds was indeed driving with a broken headlight, a state criminal traffic violation. This is not uncommon, nor is it debatable.
The discovery and search are procedures affirmed by cases New York v. Belton, 453 U.S. 454, (1981), Arizona v. Gant, 566 U.S. 332, (2009) and Wyoming v. Houghton, 526 U.S. 295, (1999). In the case of New York v. Belton, the court ruled that officers can search a car and any compartments in the car after conducting an arrest. This allows the search of the vehicle in the case of Rounds, because he was in custody in the patrol car, and he was arrested. Arizona v. Gant held that the search of a vehicle, after its occupant is arrested, is permissible if it is reasonable to believe that there is evidence linked to the arrest. Since Officer Towns first arrested and placed Rounds in the patrol car and then moved to question the opaque bag, he was in his right, especially because there was reason to believe that the contents of the bag could be linked to evidence of Rounds’s past crime: possession of marijuana. The prosecution cites Wyoming v. Houghton as well. This case dictates that as long as there is probable cause to search a vehicle, all following searches, including those of its contents are legal. Since there was probable cause to search Rounds’s vehicle, the recovery and seizure of the opaque bag was constitutional. The opaque bag revealed gift cards which were allegedly stolen, and not the marijuana that Officer Towns suspected the seizure would reveal. This
The defense chooses to cite Riley v. California, but the application of this case case to State v. Rounds is incorrect. The claim that the gift cards obtained by Officer Towns somehow equates to the cellphone seized by Riley’s arresting officer is illogical. Riley v. California classifies phones as mini-computers, having access to a cloud of information, gift cards on the other hand, are much simpler with far fewer functions. Access to these functions only reveals evidence of the specific crime Officer Towns suspected. Officer Towns suspected the cards had been stolen, a very pointed crime, one which has very direct and specific with the procedure for affirming or dismissing those suspicions. Established by both City of Indianapolis v. Edmond, 531 U.S. 32 (2000) and Michigan Dept. of State Police v. Sitz, 496 U.S. 444 (1990), as long as in the balancing test between intrusion to the motorist and the interest of government, the intrusion is minimal and closely correlated with the crime, the search is permissible. In the case of State v. Rounds the scan of the cards was protected and necessary, it was a minimal intrusion. Riley v. California held that while the officers did not have the right to search the phone without a warrant, it could have been disconnected from the network and placed in a “Faraday Bag” to protect the information on it. This cannot be applicable to gift cards. An officer on the scene cannot easily disconnect