Moreover, although they initially located no firearms, the officers found ammunition in the defendant's coat pocket and observed several rounds in his car. This evidence coupled with the fact that the officers had received a report that a vehicle similar to defendant's had been involved in a drive-by shooting, could have led the officers to reasonably believe that the vehicle contained a revolver which could pose a threat to their safety. Thus, we hold that the trial court did not err in determining that sufficient exigent circumstances existed justifying the warrantless search of defendant's vehicle. In addition, defendant asserts that the trial court erred in ruling that the police had probable cause to search his vehicle. However, defendant's brief contains no legal analysis or authority to support his argument.
Defendant simply makes the bald assertion that no probable cause existed.
It is well established that a reviewing court will not address arguments that are not adequately briefed. Therefore we affirm the trial court's ruling on this ground. Although defendant claims that the police were required to obtain a warrant before transporting his car back to Davis County to conduct the search, this argument fails because both probable cause and exigent circumstances existed here. Eyewitness Identification Defendant further argues that introduction of the eyewitness's identification violated his right to due process of law under article I, section 7 of the Utah Constitution and the Fourteenth Amendment to the United States Constitution because the identification was unreliable. The constitutionality of an identification procedure presents a mixed question of fact and law.