A police officer recovered a firearm when he conducted a warrantless search of the passengers of a car stopped for a registration violation. Was it error for a the California Court of Appeal to dispense with the usual requirement that the State is obliged to justify a warrantless search, and instead place the burden on the defendant to demonstrate the illegality of the search?

Whether the California Court of Appeal improperly shifted the burden of justifying a warrantless search from the State to the defendant