State v. Watkins, 220 N.C. App. 384 (May. 1, 2012)

The search of a vehicle driven by the defendant was valid under Gant as incident to the arrest of the defendant’s passenger for possession of drug paraphernalia. Officers had a reasonable belief that evidence relevant to the passenger’s possession of drug paraphernalia might be found in the vehicle. Additionally, the objective circumstances provided the officers with probable cause for a warrantless search of the vehicle. The drug paraphernalia found on the passenger, an anonymous tip that the vehicle would be transporting drugs, the fact that there were outstanding arrest warrants for the car’s owner, the defendant’s nervous behavior while driving and upon exiting the vehicle, and an alert by a drug-sniffing dog provided probable cause for the warrantless search of the vehicle.