Defendant’s handgun was hidden in a doghouse on the curtilage. The court distinguishes other cases allowing a search for a firearm, particularly one where a loaded shotgun was publicly put in the trunk of a car and the keys left in the lock. Here, it was well secreted and at most two people knew where it was. The government’s addition of protective sweep after the R&R is rejected as waived. United States v. Grills, 2019 U.S. Dist. LEXIS 188105 (E.D. Wis. Oct. 30, 2019).
The state police policy to impound vehicles where the driver is arrested is reasonable. The inventory policy doesn’t require searches of locked containers. It is sufficient under Wells. United States v. Thibeault, 2019 U.S. Dist. LEXIS 188123 (W.D.Okla. Oct. 30, 2019).*