Pennsylvania was one of the few remaining states not to adopt the federal automobile exception in regard to automobile searches. In Pennsylvania police officers were required to get search warrant for a car unless they could articulate a specific exception to the warrant requirement like plain view. However, in 2014 Pennsylvania adopted the federal automobile exception to the warrant requirement, requiring only probable cause as the standard for the warrantless search of a motor vehicle in Commonwealth v. Gary, 91 A.3d 102 (2014).
In Gary, the Pennsylvania Supreme Court changed the rule in a narrow decision. The Court held, where probable cause exists for a search of the car, a search warrant is not needed even if there is adequate time to get the warrant without any risk of losing evidence. The decision, however, does not discuss the the Fourth Amendment standard and/or application in other car search issues. Accordingly, any other type of issues regarding car searches remains the same. The other types of car search issues are: standing, expectation of privacy, closed containers, glove boxes, trunks, handbags, consent, search of occupants, reasons for the stop, pretextual stops, racial profiling, and checkpoint stops.
The meaning of this decision is not so impactful in Pennsylvania because frequently police searched cars without a warrant and judges were not suppressing the fruits of the illegal search. Here is an example under the new rule in Gary: the police are in a chase of a suspect in a drug dealing case where the have a description of the alleged dealer and that he also has a gun. The police eventually stop the car. The suspect matches the description identically and so does the car. They take the suspect out of the car and search him–they do not recover any narcotics or a gun. In the past, the police would have been required to obtain a search warrant for the car, now the police can simply search the car.