D.Neb.: Minor mistakes on inventory paperwork don’t make the inventory unreasonable

The officer’s minor errors on the paperwork for the inventory don’t show that was pretextual for a criminal search or otherwise unreasonable. United States v. Lillard, 2018 U.S. Dist. LEXIS 6613 (D. Neb. Jan. 16, 2018) (wrong vehicle model, failing to circle whether defendant had been arrested or not, omission of beer can in console (not a valuable item).

Defendant refused a PBT by remaining silent when asked and then put chewing tobacco in his mouth after being told that nothing should go in his mouth for the test. “Because we conclude Jones refused the PBT, the deputy properly invoked the implied consent procedure based on that refusal, and the district court was correct in denying Jones’s motion to suppress the chemical test results. We affirm Jones’s conviction and sentence.” State v. Jones, 2018 Iowa App. LEXIS 44 (Jan. 16, 2018).*

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