6 California opinions name it 2 courts 1994–2025 3 in the last five years
The cases below were cited by California 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.
| Case | Followed | Cited |
|---|---|---|
People v. Williamsgreen2 sentences2025(Dominguez, at p. 353 [relying upon a “reasonable” “inference” in applying inevitable discovery doctrine].) Third, defendant argues that the inventory search doctrine only applies to automobiles and that the People must introduce evidence of the standardized procedures followed for such auto searches (People v. Williams (1999) 20 Cal.4th 119, 138 [discussing absence of a “policy supporting an inventory search” of an automobile specifying which parts of the vehicle would be searched]). 2002(Ibid.) Citing Colorado v. Bertine, supra, 479 U.S. 367 , 107 S.Ct. 738 , 93 L.Ed.2d 739 , Williams stated that police have a legitimate interest in taking an inventory of the contents, including closed containers, in vehicles they legally tow and impound, and therefore inventory searches constitute an exception to the search warrant requirement of the Fourth Amendment. ( Williams, supra, at p. 126 , 83 Cal.Rptr.2d 275 , 973 P.2d 52 .) However, for the inventory search exception to apply, police must follow established standardized procedures. | 2 | 3 |
People v. Torresgreen2 sentences2024(People v. Lee, supra, 40 Cal.App.5th at p. 867; Blakes v. Superior Court, supra, 72 Cal.App.5th at pp. 914-915.) “Unlike the probable cause determination, which rests solely on an objective standard, the inventory search exception evaluates both the objective reasonableness of the impound decision and the subjective intent of the impounding officer to determine whether the decision to impound was ‘motivated by an improper investigatory purpose.’ [Citation.] Such purpose renders a decision to impound and the subsequent inventory search unlawful under the Fourth Amendment.” (People v. Lee, supr 2024(People v. Lee, supra, 40 Cal.App.5th at p. 867; Blakes v. Superior Court, supra, 72 Cal.App.5th at pp. 914-915.) “Unlike the probable cause determination, which rests solely on an objective standard, the inventory search exception evaluates both the objective reasonableness of the impound decision and the subjective intent of the impounding officer to determine whether the decision to impound was ‘motivated by an improper investigatory purpose.’ [Citation.] Such purpose renders a decision to impound and the subsequent inventory search unlawful under the Fourth Amendment.” (People v. Lee, supr | 1 | 3 |
Florida v. Wellsgreen2 sentences2021“Because of the risk that an inventory search will be ‘a ruse for a general rummaging,’ . . . a valid inventory search must adhere to a preexisting policy or practice.” (People v. Williams (1999) 20 Cal.4th 119, 138 (Williams).) Thus, for instance, “standardized criteria . . . or established routine, . . . must regulate the opening of containers found during inventory searches,” and the “individual police officer must not be allowed so much 11 latitude that inventory searches are turned into ‘a purposeful and general means of discovering evidence of crime.’ ” (Florida v. Wells (1990) 495 U.S. 2019(Torres, supra, 188 Cal.App.4th at p. 788 .) Officers may not use an inventory search as "a ruse for a general rummaging in order to discover incriminating evidence." (Florida v. Wells (1990) 495 U.S. 1, 4 .) Unlike the probable cause determination, which rests solely on an objective standard, the inventory search exception evaluates both the objective reasonableness of the impound decision and the subjective intent of the impounding officer to determine whether the decision to impound was "motivated by an improper investigatory purpose." (Torres, at p. 791.) Such purpose renders a decision to | 1 | 3 |
United States v. Mark Johnsongreen1 sentence2024The relevant question is whether the impounding was subjectively motivated by an improper investigatory purpose”]; and see United States v. Anderson (2024) 101 F.4th 586, 593 [impoundments and inventory searches are “the rare context where the Fourth Amendment analysis is not purely objective—subjective motivations are material”]; and United States v. Johnson (2018) 889 F.3d 1120, 1125 [“ ‘actual motivations do matter’ ” in “administrative searches conducted without individualized suspicion—such as drunk-driving checkpoints or vehicular inventory searches”].) Thus, “courts will explore police | 1 | 1 |
United States v. Jonathan Andersongreen1 sentence2024The relevant question is whether the impounding was subjectively motivated by an improper investigatory purpose”]; and see United States v. Anderson (2024) 101 F.4th 586, 593 [impoundments and inventory searches are “the rare context where the Fourth Amendment analysis is not purely objective—subjective motivations are material”]; and United States v. Johnson (2018) 889 F.3d 1120, 1125 [“ ‘actual motivations do matter’ ” in “administrative searches conducted without individualized suspicion—such as drunk-driving checkpoints or vehicular inventory searches”].) Thus, “courts will explore police | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Colorado v. Bertine
green
2 sentences2002(Ibid.) Citing Colorado v. Bertine, supra, 479 U.S. 367 , 107 S.Ct. 738 , 93 L.Ed.2d 739 , Williams stated that police have a legitimate interest in taking an inventory of the contents, including closed containers, in vehicles they legally tow and impound, and therefore inventory searches constitute an exception to the search warrant requirement of the Fourth Amendment. ( Williams, supra, at p. 126 , 83 Cal.Rptr.2d 275 , 973 P.2d 52 .) However, for the inventory search exception to apply, police must follow established standardized procedures. 2002(Ibid.) Citing Colorado v. Bertine, supra, 479 U.S. 367 , 107 S.Ct. 738 , 93 L.Ed.2d 739 , Williams stated that police have a legitimate interest in taking an inventory of the contents, including closed containers, in vehicles they legally tow and impound, and therefore inventory searches constitute an exception to the search warrant requirement of the Fourth Amendment. ( Williams, supra, at p. 126 , 83 Cal.Rptr.2d 275 , 973 P.2d 52 .) However, for the inventory search exception to apply, police must follow established standardized procedures. | 2 | 1994–2002 |
Illinois v. Lafayette
green
1 sentence2025Defendant is wrong: Inventory searches also include a defendant’s belongings upon booking (see Lafayette, supra, 462 U.S. at pp. 646-648), and we may reasonably infer that the police 10 would have opened and looked inside the backpack in defendant’s possession where, as here, there was no one else present to whom the backpack could be entrusted when defendant was arrested. | 1 | 2025–2025 |
People v. Aguilar
green
1 sentence2019(Aguilar, supra, 228 Cal.App.3d at p. 1053 .) Officer Robles's search of the Cadillac is similar to the search in Torres. | 1 | 2019–2019 |
South Dakota v. Opperman
green
2 sentences1994What the department does not expressly argue, but what we imply from its argument, is that, were Ms. Taylor's entry into Susan T.'s home pursuant to the department's authority under section 5156, that entry would fall within the inventory search exception to the warrant requirement of the Fourth Amendment under the authority of Colorado v. Bertine (1987) 479 U.S. 367 [ 93 L.Ed.2d 739 , 107 S.Ct. 738 ] and South Dakota v. Opperman (1976) 428 U.S. 364 [ 49 L.Ed.2d 1000 , 96 S.Ct. 3092 ]. 1994What the department does not expressly argue, but what we imply from its argument, is that, were Ms. Taylor's entry into Susan T.'s home pursuant to the department's authority under section 5156, that entry would fall within the inventory search exception to the warrant requirement of the Fourth Amendment under the authority of Colorado v. Bertine (1987) 479 U.S. 367 [ 93 L.Ed.2d 739 , 107 S.Ct. 738 ] and South Dakota v. Opperman (1976) 428 U.S. 364 [ 49 L.Ed.2d 1000 , 96 S.Ct. 3092 ]. | 1 | 1994–1994 |
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.