A police dispatcher broadcasted that the dispatcher had just received multiple 911 calls reporting that the driver of a blue BMW two-door convertible had fired gunshots at a group of people at a block party, injuring two people. Shortly thereafter, near the block party location, one of the officers encountered what appeared to be a recent car collision involving a blue BMW two-door convertible, which fit the description of the car involved in the block party shooting, and a Toyota Camry. Both cars' airbags had deployed, rendering them inoperable. The BMW's driver, who was standing beside the wreck, approached the officer and asked if the driver could retrieve his cell phone from the car. The officer denied the request and directed the driver to stand back from the scene. Before having the cars towed away, the officer searched the BMW and recovered a handgun that appeared to have been recently discharged.

Was the officer's search of the BMW constitutional under the automobile exception to the warrant requirement?