OH3: Impoundment of car for SW did not prohibit inventory before SW issued

The impoundment of defendant’s car was reasonable under the circumstances because officers intended to and did get a search warrant for it. The inventory before the search warrant wasn’t prejudicial because nothing from the inventory was even mentioned in the search warrant application. In the warranted search, officers sought one SD card to search. A second was found, and another search warrant was sought for it. A premature search of it was saved by inevitable discovery. State v. Workman, 2015-Ohio-5049, 2015 Ohio App. LEXIS 4895 (3d Dist. Dec. 7, 2015).

Defendant’s car was three feet from the curb, so the officer had reasonable suspicion that it was illegally parked. The officer was not required to discount that the driver was letting off passengers. He didn’t even see anybody in the vehicle at first. United States v. Rodriguez-Ramirez, 2015 U.S. Dist. LEXIS 162808 (E.D.Wis. Aug. 13, 2015).*