CA4: Inventory would happen so that’s inevitable discovery

The discovery of the contraband was by inevitable discovery because an inventory was going to occur in any event. The fact the policy wasn’t written isn’t determinative as long as it is reasonable. United States v. Bullette, 2017 U.S. App. LEXIS 6886 (4th Cir. April 20, 2017):

In short, we have never required the government to provide a written impoundment-and-inventory policy or elicit step-by-step testimony concerning such a policy to meet its burden under the inevitable-discovery doctrine. The government meets its burden and this court can affirm on inevitable-discovery grounds if the district court can assess the inevitability and reasonableness of a hypothetical inventory search from testimony provided by a law-enforcement official–such as DEA Agent Willey here. See Ford, 986 F.2d at 60; United States v. Mancera-Londono, 912 F.2d 373, 375-76 (9th Cir. 1990) (crediting DEA agent’s testimony about unwritten procedures the DEA follows for impounding and inventorying automobiles in an inevitable-discovery case); see also United States v. Agofsky, 20 F.3d 866, 872-73 (8th Cir. 1994); United States v. Frank, 864 F.2d 992, 1002-05 (3d Cir. 1988); United States v. Okiyama, No. 93-10569, 1994 U.S. App. LEXIS 13161, 1994 WL 198632, at *1 & n.1 (9th Cir. May 19, 1994) (unpublished). As explained above, the government has met its burden in this case. Therefore, we affirm the district court’s denial of Defendant’s motion to suppress.

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