50 N.E.3d 378
Ind. Ct. App.2016Background
- On Aug. 18, 2014 Officer Greathouse stopped Chauncy Rhodes for speeding, arrested him for driving on a suspended license, and decided to impound/tow the vehicle.
- Before towing, Greathouse performed an on-scene inventory search of the passenger compartment, glove box (unlocked), and trunk (unlocked) and found a metal grinder with a small amount of marijuana.
- Rhodes moved to suppress the items as obtained in an unreasonable warrantless search; the trial court denied the motion, the evidence was admitted, and Rhodes was convicted of misdemeanor possession (later enhanced to Class D felony based on a prior conviction) and driving while suspended.
- On appeal Rhodes challenged admission of the evidence; the appellate majority reviewed whether the trial court abused its discretion in admitting inventory-search evidence.
- The State failed to present the department’s written inventory policy or sufficient testimony showing the search conformed to established IMPD procedures; the only officer testimony described general practice but lacked detail and no inventory/property documentation was produced.
Issues
| Issue | Plaintiff's Argument (Rhodes) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the inventory search exception justified warrantless search/seizure of vehicle | Search was unreasonable and not shown to follow police inventory policy; items should be suppressed | Search was a routine inventory incident to impoundment and lawful; officer testified about IMPD practice | Court: Search unreasonable — State failed to prove compliance with official inventory procedures; evidence inadmissible |
| Whether trial court abused discretion by admitting evidence obtained in inventory search | Admission was error because search violated Fourth Amendment | Admission proper under inventory-search exception | Court: Admission was an abuse of discretion; conviction reversed |
| Whether impoundment legality needed resolution to decide inventory issue | Not necessary if inventory unreasonable | State relied on impoundment to justify inventory | Court: Did not decide impoundment; held inventory invalid on its own under Fair test |
| Whether appellate standard differs when suppression denial was not appealed interlocutorily | Rhodes framed appeal as abuse-of-discretion on admission; standard same as suppression review | State relied on preserved trial objection | Court: Review treats admissibility ruling similarly; consider evidence favoring trial court and uncontested facts favoring defendant |
Key Cases Cited
- Fair v. State, 627 N.E.2d 427 (Ind. 1993) (sets test for reasonableness of inventory searches and requires proof of departmental procedures)
- Edwards v. State, 762 N.E.2d 128 (Ind. Ct. App. 2002) (State must present more than bald assertion—evidence of local policy or practice required)
- Stephens v. State, 735 N.E.2d 278 (Ind. Ct. App. 2000) (example of sufficient record detail supporting routine inventory)
- Wilford v. State, 31 N.E.3d 1023 (Ind. Ct. App. 2015) (officer testimony detailing procedures can suffice to show routine inventory)
- Lundquist v. State, 834 N.E.2d 1061 (Ind. Ct. App. 2005) (standard of review for admissibility/suppression rulings)