Hand to hand drug sale — PC to arrest or search?

People v Byrd
Officers got an anonymous tip that a person in a Chevrolet Cavalier would be doing a drug deal. Later, the officers saw Byrd driving a Chevrolet Cavalier. He stopped when a woman flagged him down. Byrd opened the driver’s door, reached his hand under the car and retrieved a small black box. Byrd took tiny “shiny objects” from that black box” and gave them to the woman. The woman then gave Byrd currency.

The officers stopped Byrd moments later. Byrd had no insurance or license. The officers arrested him. An officer retrieved the black box from under the car. It contained a number of plastic square baggies with drugs in them.

The Illinois Court of Appeals ruled that there was no probable cause to (search the box) or arrest Byrd for the sale of drugs.

There are many notes that must be discussed with this:
1. Since Byrd was under arrest for the failure to have a license or insurance, the arrest was constitutional, but the drugs were suppressed.
2. I think the argument that should have been made and accepted is that a person shouldn’t have an expectation of privacy in box under his car.
3. There probably would have been PC if the officer would have stated in his report and testified about the anonymous call.
3. The officers should have filled out an inventory form.
4. The officers should have asked for consent.
Best -
DA