Ninth District Court of Appeals
State v. Chojnowski. Client charged with possession of drug abuse instruments after search of bag in a vehicle in which she was a passenger. Filed motion to suppress on the basis that driver of vehicle did not have authority to consent to search of bag, which trial court denied. On appeal, Ninth District Court of Appeals reversed trial court and established new rule of law prohibiting searches of passenger’s personal effects based solely on a driver’s consent.