TN: Where car was abandoned, there were no reasonable alternatives to impoundment available to the police

Tennessee recognizes that impoundment and inventory can be avoided if there are reasonable alternatives to it at the time. Here, defendant’s car was abandoned on the road and, when they arrived, it was in the process of being towed and searched. Thus, there were no reasonable alternatives at the time. State v. Holmes, 2022 Tenn. Crim. App. LEXIS 1 (Jan. 4, 2022).

“The Court concurs with the Magistrate Judge’s determination that the stop was not unreasonably prolonged. Contrary to Hardin’s assertion, this was not a simple matter. Officer Wiggins had reasonable suspicion that Hardin committed a serious crime that involved a minor victim. Thus, this investigation reasonably required time, attention, and care. In other contexts, courts have approved lengthy detentions when law enforcement officers acted with reasonable diligence under the circumstances to confirm or dispel their reasonable suspicion.” United States v. Hardin, 2022 U.S. Dist. LEXIS 513 (M.D.Fla. Jan. 3, 2022).*