Is a search of a toolbox by Border Patrol officers a non-routine border search?

MultiRegion, United States of America

The following excerpt is from U.S. v. Bravo, 295 F.3d 1002 (9th Cir. 2002):

Bravo argues that the search of the toolbox on his truck was a non-routine border search because it involved force and caused damage. If the search was non-routine, it must have been supported by a reasonable suspicion of illegal activity. We recently extended the non-routine border search doctrine to vehicles and other objects not just bodies. United States v. Molina-Tarazon, 279 F.3d 709 (9th Cir.2002), established a non-exhaustive list of factors to determine when a search morphs from routine to non-routine: use of force, danger to the person whose possession is being searched, and the psychological intrusiveness of the search.

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