Then what you witnessed has no bearing on what I or Motor51 was talking about; Which was search and seizure case law as it applies to vehicles stopped in a traffic stop. Vehicles that the officer did not witness moving, abandoned, etc on private property trigger a different set of more restrictive requirements. In that case, yes you would need a search warrant to search a parked and locked car on private property.
You beat me to it Joel.
JR1572