US v. Seldon: Seldon owned a Mazda MPV minivan, which he had modified to include two secret compartments to smuggle drugs. One compartment was in the gas tank. He took the MPV to a local dealership because it was "hard starting" and cutting off after starting. Given the problems, mechanics examined the fuel pump which, in a Mazda MPV, is located in the gas tank. In the course of their diagnosis, the mechanics found the secret compartment in the gas tank, as well as another one, and alerted local police. An officer went to the dealership, observed the compartments, and got information on who brought the minivan in for service. He knew that Seldon was known to local authorities as a major drug dealer. The officer did not pursue the investigation any further at that time.
As it would happen, the same officer pulled Seldon over for speeding in the minivan nine months later. During the stop, the officer noticed various indicia of narcotics trafficking (excessive use of air fresheners, large amounts of cash, Seldon's nervousness) and made the connection with the secret compartments discovered months earlier. The officer searched the minivan and found 500 grams of cocain and 850 grams of marijuana. Seldon was charged with conspiracy to distribute drugs and illegal monetary transactions. He moved to suppress the drugs found in the minivan, arguing that the officer lacked probable cause for the search incident to the traffic stop and that the initial examination at the dealership was also unconstitutional. The district court denied the motion and Seldon pleaded guilty to the charges.
On appeal, the Fourth Circuit affirmed. It rejected Seldon's argument that the initial search at the Mazda dealership violated the Fourth Amendment because the information was revealed by searches conducted by the mechanics prior to the involvement of the police, even if the officer's subsequent examination of the minivan was unlawful. With that information, along with the facts developed during the traffic stop, there was probable cause to search Seldon's vehicle.