MA: Inventory and tow was reasonable rather than leave defendant’s car in a high crime area

It was reasonable to have defendant’s vehicle inventoried and towed, rather than leave it parked in a high crime area that would have exposed it to vandalism or theft. Commonwealth v. Eddington, 76 Mass. App. Ct. 173, 920 N.E.2d 883 (2010) (“This evidence demonstrates a sufficient risk that the car might be vandalized or stolen so that, when combined with the risk of false claims for loss against the police, the impoundment of the car, pursuant to a constitutionally adequate police policy, was reasonable and thus permissible under the Fourth Amendment.”).

Defendant’s father consented to a search of his juvenile daughter’s room, and the officer also searched her purse which was not in the room. There were “widely divergent” facts in the suppression hearing, and the suppression order must be affirmed. State v. V.S., 26 So. 3d 662, 35 Fla. L. Weekly D 235 (4th DCA 2010).*

Defendant was a visitor to a motel room, and he had no reasonable expectation of privacy to challenge its search. Smith v. State, 301 Ga. App. 128, 690 S.E.2d 449 (2010).*

The trial court’s conclusion that the search of defendant’s car was valid as an inventory from his arrest was affirmed. Alternatively, the trial court’s conclusion that defendant did not consent to the search of the car is unsupported by the evidence, and that is an alternative ground. People v Concepcion, 2010 NY Slip Op 701, 69 A.D.3d 956; 893 N.Y.S.2d 283 (2d Dept. 2010).*