Commonwealth v. Eddington, 459 Mass. 102

Officers surveilled a residence after-hours party and observed Eddington and Cappas leave with beer, enter a car, and drive away.
The car was stopped for open containers; Eddington’s license was suspended, and he was arrested for operating with a suspended license.
The car’s owner was not present; registration showed the car was registered to Jessica Rodriguez, not present at the scene.
Officers decided to impound the car and conducted an inventory search, yielding a loaded revolver from the trunk; Cappas was arrested.
A superior court judge suppressed the firearm and ammunition, finding the impoundment unjustified since the car was lawfully parked.
The Appeals Court reversed, applying a multi-factor, fact-specific approach to impoundment and inventory search reasonableness; this Court granted further review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was impoundment justified to permit an inventory search?	Eddington: impoundment necessary to prevent theft/vandalism and protect against false loss claims.	Cappas: car was lawfully parked; impoundment not justified absent risk of theft or vandalism.	Yes; impoundment reasonable under the circumstances.
Did absence of the owner at the stop undermine impoundment?	Eddington: owner not present but vehicle could still be protected; no need to contact owner.	Cappas: owner absence supports consideration of impoundment and inventory search.	Owner absence does not render impoundment per se unreasonable here; circumstances justified impoundment.
Whether labeling the area as a 'high crime' area without specific facts undermines reasonableness.	Eddington: designation insufficient to justify impoundment.	Cappas: high crime area plus driver arrest supports impoundment.	Not per se, but in this case, combined factors supported reasonableness.
Is compliance with standard inventory procedures required to validate the search?	Eddington: standard procedures sufficient but impoundment must be justified.	Cappas: written procedures were followed; inventory search proper.	Yes; inventory search conducted in accordance with standard procedures was permissible.

Commonwealth v. Ellerbe, 430 Mass. 769 (Mass. 2000) (impoundment decisions and inventory search scope depend on reasonableness and context)
Commonwealth v. Brinson, 440 Mass. 609 (Mass. 2003) (impoundment justified by public safety or danger of theft/vandalism)
Commonwealth v. Daley, 423 Mass. 747 (Mass. 1996) (impoundment decisions can be evaluated case-by-case for reasonableness)
Commonwealth v. Garcia, 409 Mass. 675 (Mass. 1991) (inventory searches and impoundment concerns; three interests protected)
Commonwealth v. Caceres, 413 Mass. 749 (Mass. 1992) (opportunity for reasonable alternative arrangements; per se rules discouraged)
Commonwealth v. Johnson, 454 Mass. 159 (Mass. 2009) (high crime area term requires specific facts to justify intrusion)
Commonwealth v. Sanchez, 40 Mass. App. Ct. 411 (Mass. App. Ct. 1996) (reasonableness of seizure assessed at time of police action)