NLCRPD has posted the updated agency written directive NLCRPD 1.2.3 governing searches without a warrant on the agency webpage in the policy tab. This written directive revision reflects changes that may become procedurally necessary to comply with the determinations of the Pennsylvania Supreme Court Commonwealth v. Alexander, 30 EAP 2019 (2020) concerning warrantless vehicle searches.

On December 22, 2020, the Supreme Court of Pennsylvania explicitly overturned Com. v. Gary, 625 Pa. 183, 91 A.3d 102 (2014), the case which had adopted the federal automobile exception to the warrant requirement. Under Gary and the federal automobile exception, probable cause was all that was needed to search a vehicle and any container therein that may contain the contraband. However, in Alexander, the Supreme Court held that for a warrantless search of a vehicle to be valid, there must be a showing of both probable cause and exigent circumstances. The exigent circumstances must be more than the inherent mobility of the vehicle and the officer must be able to offer specific, articulable circumstances, known to them at the time they wish to search the vehicle, that justifies the decision that obtaining a warrant was not reasonably practicable.