Can a police officer search a vehicle in a high-crime area because the vehicle is parked in the middle of the night?

In Medina, the defendant was stopped at approximately midnight in a high-crime area because a taillight was broken. The police officer decided to conduct a search because the defendant was in a "'high-gang location.'" (People v. Medina, supra, 110 Cal.App.4th at p. 175.) The appellate court reversed the denial of the motion to suppress, finding insufficient facts to support the search. "[W]hile '[a]n area's reputation for criminal activity is an appropriate consideration in assessing whether an investigative detention is reasonable under the Fourth Amendment,' and '[t]he time of night is another pertinent factor in assessing the validity of a detention,' 'mere presence in a high crime area is not, standing alone, "sufficient to justify interference with an otherwise innocent-appearing citizen . . . . [Citation.]'" (Id. at p. 177.)

Likewise, appellant's reliance on Arizona v. Johnson (2009) 555 U.S. 323 [129 S. Ct. 781] is misplaced. There, police officers patrolling a gang neighborhood stopped a vehicle because of a suspended registration. One officer questioned the driver outside the vehicle. Another officer began questioning the defendant who was a passenger in the backseat. The defendant was wearing a bandana consistent with gang membership, and in possession of a police scanner. He informed the officer that he had served a prison sentence for burglary and had been out for about a year. The officer ordered the

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