Andre M. Huggins v. State Delaware

The officers stopped the car and took Huggins and his three confederates into custody. The officers found three small bags
of cocaine in the right rear of the Nissan, a single bag of cocaine on the ground next to the place where the police patted
down one of the suspects, and 12 small bags of cocaine under the seat of the cruiser where the police had taken another suspect
to the station.