Mike Smore V. The LSPD

In Smoore, the court established two facts relating to felony stops. First, when effectuating an arrest or once an arrest has been effectuated, police may conduct a “protective sweep” of the premises or location from which the individual is arrested or detained. This includes opening the trunk of a vehicle to inspect the trunk for occupants when an attack may be launched against the officers or others from that area. 

Secondly, that absent separate probable cause or exception (i.e. probable cause that evidence of the crimes of arrest will be found or an inventory search of a vehicle to be impounded) officers may not search the or inventory the trunk of the vehicle when performing a protective sweep, and the contents of the trunk shall not be considered to be in “plain sight” when a protective sweep is conducted.