MO: Inventory followed policy without putting it into evidence

The officer testified his inventory followed policy, but no written policy was admitted into evidence. It was up to the trial court to believe the officer on policy or not, and it did. State v. Teel, 2022 Mo. App. LEXIS 340 (May 31, 2022).

The affidavit for warrant here failed to show nexus. “In this case, it does not appear that the police conducted surveillance to determine how long the unknown male and female remained at the premises and the affidavit provided no information about the time of day they went inside. Nor is any information included about the ownership of the residence or whether the driver’s license information for the female to whom the car was registered matched a description of the unknown female who entered the residence. Finally, nothing in the affidavit shows that either occupant of the vehicle carried something believed to be illegal drugs into the residence. Based upon the totality of the particular facts and circumstances of this case, we conclude that there was not a substantial basis for concluding that probable cause existed to search the residence. … Accordingly, the trial court erred by denying this portion of Medina-Hernandez’s motion to suppress.” Medina-Hernandez v. State, 2022 Ga. App. LEXIS 264 (June 1, 2022).*

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