The following excerpt is from U.S. v. Mathnay, 895 F.2d 1418 (9th Cir. 1990):
An officer must have probable cause to believe that a container holds evidence of a crime. United States v. Licata, 761 F.2d 537, 540 (1985). A court must analyze the totality of circumstances in making probable cause determinations. Illinois v. Gates, 462 U.S. 213, 238 (1983). Probable cause does not require that the officer's belief be "correct or more likely true than false." Texas v. Brown, 460 U.S. 730, 742 (1982).
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