Cited by

Facts that may contribute toward this “fair probability” include observable signs of impairment, 10 (holding that police had probable cause to conduct a warrantless vehicle search based in part on indicia of impairment), the presence of an open bottle, d 733, 735-36 (Minn. App. 1987), rev. denied (Minn. Jan.

See, e.g., Torgerson, d at 173; Lester, d at 771

See, (holding that probable cause supported a lawful search based on “the totality of the circumstances,” which included an “officer observ[ing] defendant’s exit from his car and the passenger’s furtive gestures attempting to shield [the officer’s] view[,] .

See, (corroborated informant’s tip); (handgun in plain view); d 803, 805-08 (Minn. 1979) (furtive gestures of occupants); d 509, 510-11 (Minn. 1973) (odor of burnt marijuana).

in the belief that the automobile contains articles the officer is entitled to seize.”

in the belief that the automobile contains articles the officer is entitled to seize.”

“Probable cause to search an automobile exists where the facts and circumstances within the officer ’s knowledge and of which he has reasonably trustworthy information are sufficient in themselves to warrant a reasonable man of reasonable caution in the belief that the automobile contains articles the officer is entitled to seize.” State v. Gallagher , (citations omitted) .

See, e.g., Flowers, d at 245, 252 (holding that defendant’s “frantic, furtive mo vements” in vehicle, which lasted for about 45 seconds and during which he leaned all the way into front passenger seat, gave officers reasonable suspicion that defendant ma y have been armed and dangerous); -08 (Minn. 1 979) (determining that defendant’s “immediate exit from his car” and passenger’s “awkward movements” in attempting to shield a brown paper bag from officer’s view supported probable cause to search

And “[p] robable cause to search an automobile exists where the facts and circumstances within the officer’s knowledge and of which he has reasonably trustworthy information are sufficient in themselves to warrant a reasonable man of reasonable caution in the belief that the automobile contains articles the officer is entitled to seize.”

(noting that probable cause “exists 6 where the facts and circumstances within the officer’s knowledge and of which he has reasonably trustworthy information are sufficient in themselves to warrant a reasonable man of reasonable caution in [a] belief”).

Probable cause “exists where the facts and c ircumstances within the officer’ s knowledge and of whi ch he has reasonably trustworthy information are sufficient in themselves to warrant a reasonable man of reasonable caution in [a] belief.”

“Probable cause to search an automobile exists where the facts and circumstances within the officer’s knowledge and of which he has reasonably trustworthy information are sufficient in themselves to warrant a reasonable man of reasonable caution in the belief that the automobile contains articles the officer is entitled to seize.”

Probable cause “exists where the facts and circumstances within the officer’s knowledge and of which he has reasonably trustworthy information are sufficient in themselves to warrant a reasonable man of reasonable caution in the belief that the automobile contains articles the officer is entitled to seize.”

(holding that furtive gestures by a passenger in the defendant's vehicle may, when combined with other observations, provide a basis for probable cause to arrest).

(automobile passenger attempted to shield brown paper bag containing contraband from police officer’s view).

In arguing that the actions of Steffen violated his rights, where we intimated that when a. motor vehicle is stopped, the fact that the driver immediately exits the vehicle and makes furtive movements, while relevant, might not be enough by themselves to establish probable cause.

1 W. LaFave, Search and Seizure § 3.6(d) (1978).