inventory exception in Indiana

15 Indiana opinions name it 1 courts 1992–2023 1 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

Case	Followed	Cited
Fair v. Stategreen ind · 1993 · cited in 3 Indiana opinions naming this issue, 1994–2016 2 sentences 2016See Fair, 627 N.E.2d at 431 (“Whether either [the impoundment or inventory search] is clearly unreasonable, the search will not be upheld.) (emphasis added). 5 Rhodes correctly notes “inventory searches conducted at the impound lot by an officer assigned to such duties are preferred to searches conducted at the scene, without a warrant, by the arresting officer.” Edwards, 762 N.E.2d at 134 . 1997See Fair, 627 N.E.2d 427 ; See also Rabadi, 541 N.E.2d 271 ; Deneal v. State, 468 N.E.2d 1029 (Ind.1984); Dixon v. State, 437 N.E.2d 1318 (Ind.1982); Dearing v. State, 271 Ind. 432 , 393 N.E.2d 167 (1979).	2	3
Rabadi v. Stategreen ind · 1989 · cited in 3 Indiana opinions naming this issue, 1992–1997 2 sentences 1997See Fair, 627 N.E.2d 427 ; See also Rabadi, 541 N.E.2d 271 ; Deneal v. State, 468 N.E.2d 1029 (Ind.1984); Dixon v. State, 437 N.E.2d 1318 (Ind.1982); Dearing v. State, 271 Ind. 432 , 393 N.E.2d 167 (1979). 1997Rabadi 541 N.E.2d at 275 .	2	3
Gibson v. Stategreen indctapp · 2000 · cited in 2 Indiana opinions naming this issue, 2014–2014 2 sentences 2014Gibson v. State, 733 N.E.2d 945, 956 (Ind. Ct. App. 2000). 2014Gibson v. State, 733 N.E.2d 945, 956 (Ind. Ct. App. 2000).	2	2
Edwards v. Stategreen indctapp · 2002 · cited in 2 Indiana opinions naming this issue, 2016–2016 2 sentences 2016As stated in Edwards v. State, 762 N.E.2d 128 (Ind. Ct. App. 2002), [aff’d on reh’g, 768 N.E.2d 506 , trans. denied,] “to show that its actions come within the inventory exception, the State must do more than offer the bald allegation of law enforcement that the search was conducted as a routine inventory” for the trial court to determine if there is an evidentiary basis to evaluate whether the inventory search “was in conformity with established local law enforcement policy”. 2016See Fair, 627 N.E.2d at 431 (“Whether either [the impoundment or inventory search] is clearly unreasonable, the search will not be upheld.) (emphasis added). 5 Rhodes correctly notes “inventory searches conducted at the impound lot by an officer assigned to such duties are preferred to searches conducted at the scene, without a warrant, by the arresting officer.” Edwards, 762 N.E.2d at 134 .	1	2
Taylor v. Stategreen ind · 2006 · cited in 2 Indiana opinions naming this issue, 2008–2015 2 sentences 2015See Taylor, 842 N.E.2d at 331 . [34] Based on our review of the facts and circumstances of this case, it was reasonable under the Fourth Amendment for the police to impound the car Wilford was driving and inventory the contents before towing. 2008Id. at 330-31 .	1	2
Wilson v. Stategreen indctapp · 2012 · cited in 1 Indiana opinions naming this issue, 2023–2023 2 sentences 2023Thus, if there is a “legal ground apparent in the record” that supports the evidentiary ruling, id., we may discuss that legal ground without addressing any other potential ground, see id. [24] In this case, we accept the State’s invitation to consider whether the warrantless search satisfied an exception other than the inventory exception. 2023Thus, if there is a “legal ground apparent in the record” that supports the evidentiary ruling, id., we may discuss that legal ground without addressing any other potential ground, see id. [24] In this case, we accept the State’s invitation to consider whether the warrantless search satisfied an exception other than the inventory exception.	1	1
Ratliff v. Stategreen ind · 2002 · cited in 1 Indiana opinions naming this issue, 2023–2023 1 sentence 2023See Ratliff v. State, 770 N.E.2d 807, 809 (Ind. 2002) (affirming on different constitutional grounds the decision to admit evidence from a search); Wilson v. State, 966 N.E.2d 1259, 1263 (Ind. Ct. App. 2012) (same), trans. denied.	1	1
Colorado v. Bertinegreen scotus · 1987 · cited in 1 Indiana opinions naming this issue, 1998–1998 2 sentences 1998See Bertine, 479 U.S. at 372 , 107 S.Ct. 738 . 1998See Bertine, 479 U.S. at 372 , 107 S.Ct. 738 .	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (10)

Case	Cited	Years
Deneal v. State green ind · 1984 2 sentences 1997See Fair, 627 N.E.2d 427 ; See also Rabadi, 541 N.E.2d 271 ; Deneal v. State, 468 N.E.2d 1029 (Ind.1984); Dixon v. State, 437 N.E.2d 1318 (Ind.1982); Dearing v. State, 271 Ind. 432 , 393 N.E.2d 167 (1979). 1994Fair v. State (1993), Ind., 627 N.E.2d 427 ; see also Rabadi v. State (1989), Ind., 541 N.E.2d 271 ; Deneal v. State (1984), Ind., 468 N.E.2d 1029 ; Dixon v. State (1982), Ind., 437 N.E.2d 1318 ; Dearing v. State (1979), Ind., 393 N.E.2d 167 .	2	1994–1997
Dixon v. State green ind · 1982 2 sentences 1997See Fair, 627 N.E.2d 427 ; See also Rabadi, 541 N.E.2d 271 ; Deneal v. State, 468 N.E.2d 1029 (Ind.1984); Dixon v. State, 437 N.E.2d 1318 (Ind.1982); Dearing v. State, 271 Ind. 432 , 393 N.E.2d 167 (1979). 1994Fair v. State (1993), Ind., 627 N.E.2d 427 ; see also Rabadi v. State (1989), Ind., 541 N.E.2d 271 ; Deneal v. State (1984), Ind., 468 N.E.2d 1029 ; Dixon v. State (1982), Ind., 437 N.E.2d 1318 ; Dearing v. State (1979), Ind., 393 N.E.2d 167 .	2	1994–1997
Dearing v. State green ind · 1979 2 sentences 1997See Fair, 627 N.E.2d 427 ; See also Rabadi, 541 N.E.2d 271 ; Deneal v. State, 468 N.E.2d 1029 (Ind.1984); Dixon v. State, 437 N.E.2d 1318 (Ind.1982); Dearing v. State, 271 Ind. 432 , 393 N.E.2d 167 (1979). 1997See Fair, 627 N.E.2d 427 ; See also Rabadi, 541 N.E.2d 271 ; Deneal v. State, 468 N.E.2d 1029 (Ind.1984); Dixon v. State, 437 N.E.2d 1318 (Ind.1982); Dearing v. State, 271 Ind. 432 , 393 N.E.2d 167 (1979).	2	1994–1997
Edwards v. State green indctapp · 2002 1 sentence 2016As stated in Edwards v. State, 762 N.E.2d 128 (Ind. Ct. App. 2002), [aff’d on reh’g, 768 N.E.2d 506 , trans. denied,] “to show that its actions come within the inventory exception, the State must do more than offer the bald allegation of law enforcement that the search was conducted as a routine inventory” for the trial court to determine if there is an evidentiary basis to evaluate whether the inventory search “was in conformity with established local law enforcement policy”.	1	2016–2016
Florida v. Wells green scotus · 1990 1 sentence 2015Id. at 133 . [30] Here, the search was conducted on scene prior to towing, which Officer Raiso- *1033 vich testified was standard IMPD procedure.	1	2015–2015
Alford v. State green ind · 1998 1 sentence 2006Alford, 699 N.E.2d at 250 .	1	2006–2006
Stephens v. State green indctapp · 2000 1 sentence 2002Stephens, 735 N.E.2d at 282 .	1	2002–2002
Moore v. State green indctapp · 1994 1 sentence 2000Moore, 637 N.E.2d at 819 .	1	2000–2000
South Dakota v. Opperman green scotus · 1976 2 sentences 1994The Supreme Court of the United States first recognized the so-called “inventory ex- 815 eeption” in South Dakota v. Opperman, 428 U.S. 364 , 96 S.Ct. 3092 , 49 L.Ed.2d 1000 (1976). 1994The Supreme Court of the United States first recognized the so-called “inventory ex- 815 eeption” in South Dakota v. Opperman, 428 U.S. 364 , 96 S.Ct. 3092 , 49 L.Ed.2d 1000 (1976).	1	1994–1994
Isom v. State green indctapp · 1992 1 sentence 1993Isom v. State (1991), Ind.App., 589 N.E.2d 245, 246 , trans. denied.	1	1993–1993

Statutes the citing opinions construe

IN § Ind. Code § 35-48-4-6 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 20 (1990–2015) OH 17 (1989–2021) IN 15 (1992–2023) LA 14 (1980–2018) WA 11 (1968–2019) MI 9 (1976–2021) NY 9 (1968–2021) OR 8 (2012–2021) ID 8 (1992–2025) IL 8 (1978–2025) VA 7 (1980–2024) NM 5 (1993–2025) MA 5 (1990–2015) MN 5 (1997–2016) WY 4 (2013–2025) WI 4 (1942–2024) MD 4 (1975–2017) IA 4 (1984–2024) CA 4 (1967–2023) KS 3 (2018–2019) PA 3 (1978–2020) NE 3 (1990–2000) CO 3 (1985–2021) FL 3 (1981–2025) GA 2 (2014–2014) ND 2 (1985–2013) CT 2 (1991–1993) NH 2 (2000–2003) MS 2 (2001–2005) AK 2 (1982–1996) AL 2 (1986–1993)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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