The Government’s case against Rodgers is a criminal case, arising out of the Government’s unconstitutional search of Rodgers’s vehicle. This Court should grant Rodgers’s motion to suppress evidence because the Government cannot meet its burden of proving that this unconstitutional search falls within any established exception to the Fourth Amendment warrant requirement. The Government cannot establish the exceptions of officer safety or that the vehicle contains evidence of the offense of arrest. Sindell handcuffed and arrested Rodgers for unpaid traffic tickets. When the search took place, Rodgers was unable to reach inside the vehicle or the passenger compartment, so he was not a threat to the officers. Accordingly, this Court should
