Category Archives: Inventory

Cal.1: Inventory of duffle bag at booking was reasonable

Defendant refused to leave a 24 hour restaurant after being asked several times, and the police were called. Finally, defendant was arrested and taken into custody. His duffle bag was inventoried at the police station and a .38 revolver and … Continue reading

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WI: Community caretaking function can support impoundment and inventory despite lack of standardized procedures

Defendant matched the description of a man wanted for robbery and a probation violation. He was found on the property of a storage unit company. After his arrest, his vehicle was parked between two rows of buildings, blocking one unit … Continue reading

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IA: Unnecessary to seek out somebody else not at scene to retrieve car when driver and only passenger arrested

The state showed the impoundment policy was standardized and complied with. It wasn’t necessary at the time to seek out somebody else to retrieve the car from the roadside when both the driver and passenger were arrested. State v. Tronca, … Continue reading

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OH8: Checking under the hood during an inventory search is reasonable

Checking under the hood during an inventory search is reasonable. State v. Lewis, 2017-Ohio-4300, 2017 Ohio App. LEXIS 2352 (8th Dist. June 15, 2017). The totality and detail of information from the CI provided the police reasonable suspicion to stop … Continue reading

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CT: Slight difference between description and actual dress didn’t undermine RS

Defendant’s request to stop by the police based on his description and clothing was still justified despite the slight disagreement between what he was wearing and the description. Reasonable suspicion developed and defendant’s pat down was justified. State v. Lewis, … Continue reading

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KS: State’s failure to prove the inventory policy was fatal to the inventory search

State’s failure to prove the inventory policy was fatal to the inventory search. State v. Baker, 2017 Kan. LEXIS 310 (June 9, 2017):

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ND: Consent to search to prevent towing and impoundment of a vehicle is voluntary

Consent to search to prevent towing and impoundment of a vehicle is voluntary. State v. Shick, 2017 ND 134, 2017 N.D. LEXIS 131 (June 7, 2017). Officers got a call about a possible drunk driver, and they went to the … Continue reading

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OH1: Where inventory ordinance required police consider alternatives to impoundment, failure to do so leads to suppression

Cincinnati Municipal Code requires alternatives to impoundment be considered, and a failure to do so can void the inventory, as here. “Ultimately, nothing presented at the suppression hearing indicates that before ordering the inventory search, Officer Clarkson even considered the … Continue reading

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W.D.Mo.: Driveway not curtilage for dog sniff of car

Relying on United States v. Beene, 818 F.3d 157 (5th Cir. 2016) (posted here), defendant’s car parked on the driveway in front of his home was subject to a dog sniff as if it was on the street. Because of … Continue reading

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N.D.Ala.: Police had discretion to return car to rental company after inventory search

Police had the discretion under the inventory policy to conduct the inventory and then allow the car to go back to Enterprise car rental rather than the police impound lot. Also, a disturbed panel in the car permitted the inventory … Continue reading

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