NY: Inventory policies don’t have to be in writing to be reasonable

“There is no requirement that an inventory search protocol be written …, and courts will not ‘micromanage the procedures used to search properly impounded cars’ … ‘[R]easonable police regulations relating to inventory procedures administered in good faith satisfy the Fourth Amendment, even though courts might as a matter of hindsight be able to devise equally reasonable rules requiring a different procedure’ (Bertine, 479 U.S. at 374).” People v. Douglas, 2023 NY Slip Op 05350, 2023 N.Y. LEXIS 1825 (Oct. 24, 2023).

Defendant was found nearly unconscious half in and half out of his car with pill bottles and money around him. The search of his backpack for other possible causes of his condition and who he was was reasonable because of the exigency. He couldn’t even say who he was. Commonwealth v. Williams, 2023 Pa. Super. LEXIS 493 (Oct. 24, 2023).*

A RICO six victim murder case: “Accordingly, we conclude that the District Court did not clearly err in finding that any misstatements or omissions in Detective Rossiter’s affidavit were inadvertent, and that, even excluding E.G.’s account, the affidavit contained a sufficient basis for the magistrate’s probable cause determination.” United States v. Savage, 2023 U.S. App. LEXIS 28177 (3d Cir. Oct. 24, 2023).* (The case numbers are from 2014 and it was argued December 2022.)

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