N.D.Iowa: Inventory “policy’s language that the inventory must be ‘thorough and uniform’” is not “unconstitutional per se”

An inventory “policy’s language that the inventory must be ‘thorough and uniform’” is not “unconstitutional per se.” United States v. Perez-Trevino, 2016 U.S. Dist. LEXIS 61447 (N.D.Iowa May 10, 2016)*:

The court finds that the Policy provides sufficiently standardized criteria, making inventory searches pursuant to it constitutional. This is especially true when officers are guided by the Policy’s overarching concern with “protect[ing] the officer from liability of assumed damages and/or missing property” from the vehicle. … Furthermore, a directive that officers search the vehicle’s “compartments” plainly encompasses the vehicle’s center console where Officer Fisher discovered the marijuana and the driver’s side door where Officer Fisher discovered the methamphetamine field test kits. See, e.g., United States v. Ball, 804 F.3d 1238, 1241 (8th Cir. 2015) (finding an inventory search of a vehicle’s air filter compartment valid where the policy directs officers to search in “areas where an owner or operator would ordinarily place or store property or equipment”); United States v. Pappas, 452 F.3d 767, 772 (8th Cir. 2006) (finding an inventory search of the vehicle’s engine compartment is a proper area for an inventory search); United States v. Barry, 98 F.3d 373, 376-77 (8th Cir. 1996) (finding an inventory search of a vehicle’s unlocked glove compartment to be valid). Accordingly, the court shall overrule the Objections to the extent that they argue that the marijuana or methamphetamine field test kits should be suppressed.