A passenger in a vehicle to be inventoried after a stop is entitled to notice to retrieve her personal belongings before it happens. Only this is consistent with the purpose of the inventory requirement. Other states are in accord, and this is decided under the state constitution. State v. Fulmer, 366 Ore. 224 (Mar. 5, 2020), rev’g State v. Fulmer, 296 Ore. App. 61, 437 P.3d 257 (2019).
Armed with a parole violation warrant, officers knew defendant was at his girlfriend’s house so they entered. The entry didn’t violate the Fourth Amendment. Once they were inside, the girlfriend consented to a search that revealed the firearm. United States v. Curry, 2020 U.S. Dist. LEXIS 38943 (S.D. N.Y. Mar. 5, 2020).*