This "prohibition against unreasonable searches and seizures applies to the seizures of the person, including the brief investigatory stops such as the stop of a vehicle." Howard v. State , 987 So. 2d 506, 509 (¶12) (Miss. Ct. App. 2008). "And the ‘fruit of the poisonous tree’ doctrine makes inadmissible tangible evidence obtained incident to an unlawful search or seizure."

Moreover, "no warrant is required to seize an object in plain view when viewed by an officer from a place he has the lawful right to be, its incriminating character is readily apparent and the officer has a lawful right of access to the evidence." Howard v. State, 987 So.2d 506, 510(13) (Miss.Ct.App. 2008) (citation omitted). ¶ 31.

“Probable cause is determined by looking at the totality of the circumstances.” Howard v. State, 987 So.2d 506, 510 (¶ 12) (Miss.Ct.App.2008) (citation and quotations omitted). ¶ 15.

"Probable cause is determined by looking at the totality of the circumstances." Howard v. State, 987 So. 2d 506, 510 (¶ 12) (Miss. Ct. App. 2008) (citation and quotations omitted). 15. ¶ "[D]uring a lawful traffic stop an officer may order a passenger out of the car as a precautionary measure, without reasonable suspicion that the passenger poses a safety risk."

To determine whether probable cause exists, we must look at the " the totality of the circumstances[,]" viewing the evidence " in light of the observations, knowledge, and training of the law enforcement officers involved in the warrantless search." Howard v. State, 987 So.2d 506, 510 (¶ 12) (Miss.Ct.App.2008) (quoting Comby v. State, 901 So.2d 1282, 1286 (¶ 7) (Miss.Ct.App.2004)). We must look at " what the officers knew before they initiated the search" in order to determine whether the suspicion for the stop was reasonable.