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The “automobile exception” has been greatly expanded since Carroll v. United States (1925). For example, the Court held in California v. Carney that a mobile home capable of traveling on a highway was included within the exception. Further, in 1999, in Wyoming v. Houghton the Court held that the police may use the exception to search the personal belongings of passengers but not the passengers themselves.
The following is an example of a case law referring to the automobile exception:
The automobile exception to the warrant requirement permits warrantless searches of any part of a vehicle that may conceal evidence where there is probable cause to believe that the vehicle contains evidence of a crime. [United States v. McGlory, 968 F.2d 309 (3d Cir. Pa. 1992)].