944
Stevens, J., dissenting
403 U. S. 443 . . . (1971))." Id., at 95, 669 A. 2d, at 921 (emphasis added). From that point onward, the only reference to federal law in the decision's remaining 30 citations is a recognition that White, the sole decision of this trio of "exigent circumstance" cases that is not before our Court, was "based upon" that Court's analysis of Chambers. 543 Pa., at 99-100, 669 A. 2d, at 923-924. Every other citation in Labron is to Pennsylvania law.
Because White was issued on the same day as Labron and reached an identical conclusion regarding the "exigent circumstances" rule, that decision is worth reviewing. In White, the court hesitated before considering the merits of the case "to address the Commonwealth's claim that White has waived his claim that the search of his automobile was illegal under Article I, Section 8 of the Pennsylvania Constitution because he did not set forth his state constitutional claims in the manner required." The Commonwealth's claim, the court found, was "meritless." "White clearly raises a claim under the Pennsylvania Constitution, cites cases in support of his claim, and relates the cases to the claim. That is sufficient." 543 Pa., at 50, 669 A. 2d, at 899.
Having established the importance of the state constitutional claim to the defendant's argument, White went on to discuss the "exigent circumstance" exception at issue here in light of both federal and state law. And although the court's analysis relied upon our decision in Chambers v. Maroney, it cited none of the subsequent cases in which this Court has effectively converted the "automobile exception" into an absolute rule allowing searches in the presence of probable cause. See 543 Pa., at 49-53, 669 A. 2d, at 899-901; n. 6, infra (noting that the Pennsylvania courts' failure to refer to this Court's subsequent decisions in this area may be intentional rather than ignorant). Stressing the independent evaluation it makes of its State Constitution, the Pennsylvania court also rejected our decision in New York v. Belton,
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