Whether the California Court of Appeal improperly shifted the burden of justifying a warrantless search from the State to the defendant

A police officer recovered a firearm when he conducted a warrantless search of the passengers of a car stopped for aregistration violation. Was it error for a the California Courtof Appeal to dispense with the usual requirement that the Stateis obliged to justify a warrantless search, and instead place theburden on the defendant to demonstrate the illegality of thesearch?