MI: Inventory policy doesn’t have to be written if it’s standardized

A written search inventory policy isn’t constitutionally required. “We hold that, in order to establish that an inventory search is reasonable, the prosecution must establish that an inventory-search policy existed, all police officers were required to follow the policy, the officers actually complied with the policy, and the search was not conducted in bad faith. Whether the policy is or is not in writing should not itself be dispositive of the constitutional question.” The state did not argue suppression was not an appropriate remedy in the trial court, so that’s waived for appeal. People v. Swenor, 2021 Mich. App. LEXIS 1822 (Mar. 18, 2021).

Successive post-conviction petition over defendant’s search claim was known all along and couldn’t now be brought because the issue isn’t newly discovered. State v. Vinson, 2021-Ohio-836, 2021 Ohio App. LEXIS 822 (10th Dist. Mar. 18, 2021).*

Defendant’s 2254 Fourth Amendment ineffective assistance of counsel claim is denied. The state court’s resolution of his claims was not contrary to clearly established law. Carley v. Neven, 2021 U.S. Dist. LEXIS 51088 (D. Nev. Mar. 17, 2021).*