Jeremy was pulled over by Officer Nozey for an expired tag. Upon approaching the driver's side of Jeremy's car, Officer Nozey sees Jeremy struggling to hide something in the middle console. Believing that Jeremy might pose a threat or was engaging in illegal activity, Officer Nozey told him to exit the car, handcuffed him, opened the console, found his cell phone, and without touching it he was able to read a text message that Jeremy was about to send, which stated, "OMG, I'm getting pulled over and my trunk is LOADED".

Following the Fourth Amendment's three-step analysis analyze the scenario involving Officer Nozey and Jeremy.