{"id":6841,"date":"2012-08-25T12:41:51","date_gmt":"2012-03-18T11:13:01","guid":{"rendered":""},"modified":"-0001-11-30T00:00:00","modified_gmt":"2012-03-18T11:13:01","slug":"en-US","status":"publish","type":"post","link":"https:\/\/fourthamendment.com\/?p=6841","title":{"rendered":"CA4: Finding ammo during inventory permitted search for a gun in locked compartment"},"content":{"rendered":"

While inventory does not permit forcing open locked compartments in a car, the finding of ammunition in this car justified a further search for a gun. That was inevitable discovery. Essentially, where there’s ammunition there’s probably a gun. United States v. McCullum<\/a>, 469 Fed. Appx. 194 (4th Cir. 2012):<\/p>\n

Although the policy did not permit officers to force open a locked glove compartment during an inventory search, the ammunition discovered in the trunk would have provided probable cause to conduct a warrantless search of the vehicle for the gun associated with the seized ammunition. See Michigan v. Thomas, 458 U.S. 259, 260-62 (1982) (explaining that evidence seized during an inventory search of a vehicle can provide probable cause to search elsewhere in the vehicle for additional contraband). The scope of that warrantless search would have included “every part of the vehicle and its contents that may [have] conceal[ed] the object of the search.” United States v. Ross, 456 U.S. 798, 825 (1982). Because a glove box can conceal a gun, the glove box of the Cadillac was obviously within the scope of the warrantless probable cause search. The fact that the glove box was locked would not prevent us from upholding the lawfulness of its search. “[I]f the police have probable cause to believe that there is contraband . . . anywhere in the car they can search for it even if it is in a … locked compartment such as the glove compartment ….” United States v. Mazzone, 782 F.2d 757, 760 (7th Cir. 1986); see also Ross, 456 U.S. at 823 (“The scope of a warrantless search based on probable cause is no narrower … than the scope of a search authorized by a warrant supported by probable cause.”). Accordingly, we affirm the district court’s denial of the motion to suppress because the marijuana, the clip of ammunition, and the gun would have been inevitably discovered.<\/p><\/blockquote>\n","protected":false},"excerpt":{"rendered":"

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