Just a guess but I suspect it's both the distance and how it was placed in the v...

Jtsummers on Jan 23, 2012 | parent | context | favorite | on: Supreme Court rules 9-0 that warrant absolutely ne...

Just a guess but I suspect it's both the distance and how it was placed in the vehicle. The police did not put it in themselves, they placed it in a container that was loaded into the vehicle by the seller/suspect.