W.D.Pa.: Leaving car in street after being taken away by ambulance after being shot justified impoundment and inventory of the car

Defendant called the police because he was shot in the chest while in his car. An ambulance arrived and took defendant to the hospital. His car was left in the middle of the street. Impoundment of the car and inventory discovering drugs was proper. At the hospital, hospital security turned over to the police defendant’s personal effects including five cell phones and crack cocaine the medical staff found hidden under his scrotum. This was a private seizure. The warrant for the cell phones was based on probable cause. United States v. Lawrence, 2016 U.S. Dist. LEXIS 43735 (W.D.Pa. March 31, 2016).

Defendant was identified as a drug dealer by two CIs, and IDed him by a unique facial feature. Police set up surveillance of where he was dealing from. Gaunt men would enter with defendant with nothing in their hands and come out in three minutes with their hands in their pockets. The government proved reasonable suspicion by a preponderance of the evidence. United States v. Brown, 2016 U.S. Dist. LEXIS 44527 (E.D.Va. March 31, 2016).*