its contents that may conceal the object of the search.” United States v. Ross, 456 U.S. 798, 825, 102 S.Ct. 2157, 72 L.Ed.2d 572 (1982); see also Arizona v. Gant, 556 U.S. 332, 347, 129 S.Ct. 1710, 173 L.Ed.2d 485 (2009) (noting that “[i]f there is probable cause to believe a vehicle contains evidence of criminal activity,” the automobile exception “authorizes a search of any area of the vehicle in which the evidence might be found”). The scope of the search was therefore clearly within the boundaries of the automobile exception. The timing of the search of the car at the airport was similarly permissible. Delays in automobile searches of several hours, or even days, have been found constitutional. See United States v. Johns, 469 U.S. 478, 487-88, 105 S.Ct. 881, 83 L.Ed.2d 890 (1985) (<HOLDING>); United States v. Harwood, 998 F.2d 91, 97 (2d
holding that delay of three days was reasonable and consistent with our precedent involving searches of impounded vehicles holding a three and onehalf year delay was unreasonable holding that twoyear delay was not reasonable holding delay of 51 days to be unreasonable holding that delay in excess of three years after conclusion of direct review does not constitute reasonable diligence