S.D.Fla.: Generically describing in an inventory “tools” and “misc items” was constitutionally adequate to show true inventory

Describing a lot of stuff in defendant’s car as “tools” and “misc items” was good enough. “Officer Jas also testified that having the inventory search recorded in his BWC served to verify the accuracy of his paperwork. Having considered Officer Jas’ credible testimony, the undersigned finds that he adequately complied with MBPD SOP #133 and that the minor shortcomings argued by Defendant did not transform the inventory search into an investigatory one. Wells, 495 U.S. at 4; Williams, 936 F.2d at 1248.” United States v. Goldammer, 2019 U.S. Dist. LEXIS 58571 (S.D. Fla. Apr. 5, 2019).

Defendants get qualified immunity: “Given that defendants could have reasonably believed their actions were authorized under Summers, they are also entitled to qualified immunity on Gillen’s analogous state law claims.” Gillen v. Town of Hayden, 2019 U.S. App. LEXIS 9955 (9th Cir. Apr. 4, 2019).*