Supreme Court of Georgia
Caffee v. the State.
May 7, 2018814 S.E.2d 386
Summary
The Supreme Court of Georgia affirmed the Court of Appeals, holding that probable cause alone does not justify a warrantless search; however, because Deputy Patterson had probable cause to arrest Caffee for marijuana possession, the warrantless search of Caffee’s shirt pocket was valid as a search incident to that arrest. The Court also rebuked the appellate court for supplementing the trial court’s factual findings. The decision rests on the Fourth Amendment’s warrant requirement and the established search‑incident‑to‑arrest exception.