State of Louisiana v. Melvin Miguel

Summary

The Supreme Court of Louisiana reversed the Court of Appeal and reinstated the district court’s denial of the defendant’s motion to suppress the prescription bottle, holding that the plain‑view exception applied because the totality of the circumstances gave the detective probable cause that the bottle contained contraband. The Court clarified that the “immediately apparent” requirement of plain view is satisfied by probable cause, not by certainty, and therefore the warrantless seizure was lawful.