CA9: Under local PD policy, envelope could be opened during inventory of car

Defendant’s rental car was to be towed, and it was to be inventoried, and defendant asked that his stuff be safeguarded. “The officers followed the Seattle Police Department’s standard inventory policy, which requires officers to search for contraband, narcotics, explosives, hazardous materials, perishable items, money and weapons. This necessarily involves looking within closed containers, thus making the officers’ search of defendant’s sealed envelopes reasonable under the Fourth Amendment.” United States v. Unakalu, 455 Fed. Appx. 730 (9th Cir. 2011).

Officers found a vehicle in a one car crash with blood, but no driver or passengers were around. The officers went to the house of the registered owner and found blood on the doorknob and a key in the lock with the door unlocked. They entered to check on the owner and found her in bed with blood on her. She was intoxicated. “‘The right of the police to enter and investigate in an emergency without accompanying intent to either search or arrest is inherent in the very nature of their duties as peace officers. ***.’ United States v. Barone (C.C.A.2), 330 F.2d 543, at 545.” “We find the factual circumstances surrounding the entry into Appellee’s home justified the officer’s entering without a search warrant to ensure Appellee was not in need of medical attention due to injuries sustained in the accident.” State v. Wilson, 2011 Ohio 5371, 2011 Ohio App. LEXIS 4408 (5th Dist. October 18, 2011).

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