Does a search warrant need to state the name of the driver and correct license number of the vehicle to be searched?

While it is not necessary that a search warrant state the name of the owner or a correct license number of the automobile to be searched (Wangrow v. United States (8th Cir. 1968) 399 F.2d 106, 115, cert. den. (1968) 393 U.S. 933, 89 S.Ct. 292, 21 L.Ed.2d 270), we conclude that a warrant supporting the search of a motor vehicle must, at the very least, include some explicit description of a particular vehicle or of a place where a vehicle is later found. (See generally Note, 47 A.L.R.2d 1444.) Inasmuch as the warrant in the present case described neither the vehicle nor the site of the vehicle, it cannot serve to validate the search.

We must therefore determine whether the circumstances of the case justified a warrantless search. With respect to this issue, the People carry the burden of proving the search reasonable. (Badillo v. Superior Court (1956) 46 Cal.2d 269, 272, 294 P.2d 23.) ⁶