inventory exception (New York) · Go Syfert
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inventory exception in New York

9 New York opinions name it 3 courts 1968–2021 1 in the last five years

The cases below were cited by New York 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 (3)

CaseFollowedCited
Colorado v. Bertinegreen
scotus · 1987 · cited in 4 New York opinions naming this issue, 1990–2021
2 sentences

2021In a concurring opinion, Justice Blackmun, joined by two other Justices, reiterated [*8]that "[t]he underlying rationale for allowing an inventory exception to the Fourth Amendment warrant rule is that police officers are not vested with discretion to determine the scope of the inventory search" ( id. at 376 ).

1995The purpose of such a search, of course, is not to uncover evidence of crime but simply to produce "a detailed and carefully recorded inventory [to] protec[t] the seized property while it is in police hands and [to] insur[e] against claims of loss, theft or vandalism.” (People v Galak, supra, at 720.) In assessing, then, whether a search may be sustained as falling within the inventory exception to the warrant requirement, it is necessary to determine whether the search was in fact performed for the purpose of producing an inventory and whether the inventorying officer’s discretion respecting

14
People v. Galakgreen
ny · 1993 · cited in 1 New York opinions naming this issue, 1995–1995
2 sentences

1995The purpose of such a search, of course, is not to uncover evidence of crime but simply to produce "a detailed and carefully recorded inventory [to] protec[t] the seized property while it is in police hands and [to] insur[e] against claims of loss, theft or vandalism.” (People v Galak, supra, at 720.) In assessing, then, whether a search may be sustained as falling within the inventory exception to the warrant requirement, it is necessary to determine whether the search was in fact performed for the purpose of producing an inventory and whether the inventorying officer’s discretion respecting

1995The purpose of such a search, of course, is not to uncover evidence of crime but simply to produce "a detailed and carefully recorded inventory [to] protec[t] the seized property while it is in police hands and [to] insur[e] against claims of loss, theft or vandalism.” (People v Galak, supra, at 720.) In assessing, then, whether a search may be sustained as falling within the inventory exception to the warrant requirement, it is necessary to determine whether the search was in fact performed for the purpose of producing an inventory and whether the inventorying officer’s discretion respecting

11
State v. Montaguegreen
wash · 1968 · cited in 1 New York opinions naming this issue, 1968–1968
1 sentence

1968Unless the search is incident to an arrest, I would insist that the police obtain a warrant to search a man’s car just as they must do when they search his home.” (Three other Justices joined with Douglas, J., as dissenters in Cooper.) This thesis has likewise been advanced by the Supreme Court of Washington in the case of State v. Montague ( 438 P. 2d 571, 574 [Wash., 1968]) in which it was held, albeit dictum, “ What is now frequently referred to as the inventory rule will not apply, however, and evidence of crime discovered during the taking of the inventory will be suppressed as evidence,

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
People v. Eastern Ambulance Service, Inc. green
nyappdiv · 1984
1 sentence

2004Moreover, borrowing from criminal law, "[t]he Statute of Limitations of a continuous crime is governed by the termination and not the starting date of the offense." ( People v. Eastern Ambulance Service, Inc. , 106 AD2d 867, 868 .) Fifth, the inventory clause in the policy does not bar plaintiff OTC's claim because this is not a case where an insured discovered a theft while taking inventory, and the interpretation placed on the inventory clause by the defendant insurer is commercially unreasonable.

12004–2004
Best v. New York State Liquor Authority neutral
nyappdiv · 1982
1 sentence

2000Auth., 59 NY2d 906, revg 89 AD2d 893 for reasons stated in dissenting mem of Lazer, J., at 893-894).

12000–2000
MATTER OF BEST v. New York State Liquor Auth. neutral
ny · 1983
1 sentence

2000Auth., 59 NY2d 906, revg 89 AD2d 893 for reasons stated in dissenting mem of Lazer, J., at 893-894).

12000–2000
People v. Turriago green
ny · 1997
1 sentence

1997The People’s alternative argument, that evidence of the gun should be admitted under the inventory exception, ignores the fact that the exception is only applicable to secondary evidence (People v Turriago, 90 NY2d 77, 85-86 ; People v Stith, 69 NY2d 313, 319-320 ; People v Silver, 178 AD2d 499, 500 , lv denied 79 NY2d 953 ).

11997–1997
People v. Silver green
nyappdiv · 1991
1 sentence

1997The People’s alternative argument, that evidence of the gun should be admitted under the inventory exception, ignores the fact that the exception is only applicable to secondary evidence (People v Turriago, 90 NY2d 77, 85-86 ; People v Stith, 69 NY2d 313, 319-320 ; People v Silver, 178 AD2d 499, 500 , lv denied 79 NY2d 953 ).

11997–1997
People v. Stith green
ny · 1987
2 sentences

1997The People’s alternative argument, that evidence of the gun should be admitted under the inventory exception, ignores the fact that the exception is only applicable to secondary evidence (People v Turriago, 90 NY2d 77, 85-86 ; People v Stith, 69 NY2d 313, 319-320 ; People v Silver, 178 AD2d 499, 500 , lv denied 79 NY2d 953 ).

1997It is inapplicable in the circumstances at bar where the evidence of the gun is “primary” evidence, i.e., “the very evidence obtained in the illegal search” (People v Stith, supra, at 318 ).

11997–1997
People v. Gonzalez green
ny · 1984
1 sentence

1990"The underlying rationale for allowing an inventory exception to the Fourth Amendment warrant rule is that police officers are not vested with discretion to determine the scope of the inventory search.” (Colorado v Bertine, 479 US 367, 376 , supra [Black-mun, J., concurring].) Here, the People failed to establish that the officer, in pulling out the rear seat of defendant’s vehicle, acted in accordance with standardized procedures for inventory searches (cf., People v Gonzalez, supra).

11990–1990
Paltrovitch v. Phœnix Insurance Co. of Hartford neutral
· 1894
1 sentence

1989Co., 143 NY 73, 77 .) In any event, the issue of plaintiff’s compliance with the inventory requirement, as well as waiver, presents questions of fact for resolution at trial.

11989–1989
Miller v. State green
fladistctapp · 1962
1 sentence

1968Miller v. State, 137 So. 2d 21 (Fla. App. 1962).” While not exactly apposite but nevertheless significant as bearing on the issue presented in the instant case is the recent ruling of the Supreme Court in Camara v. Municipal Ct. ( 387 U. S. 523 [1967]).

11968–1968
Camara v. Municipal Court of City and County of San Francisco green
scotus · 1967
1 sentence

1968Miller v. State, 137 So. 2d 21 (Fla. App. 1962).” While not exactly apposite but nevertheless significant as bearing on the issue presented in the instant case is the recent ruling of the Supreme Court in Camara v. Municipal Ct. ( 387 U. S. 523 [1967]).

11968–1968

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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