People v. Vaughn
2014 CO 71
| Colo. | 2014Background
- Police stopped Vaughn for an observed traffic violation and checked license/registration via in-car system and DMV hotlines; license was suspended and registration did not match the vehicle; Vaughn was taken into custody after arrest for driving with a suspended license; the vehicle was towed and inventoried under APD policy prior to impoundment; crack cocaine was found in the glove compartment during the inventory search; trial court suppressed the evidence, ruling the search lacked proper probable cause or authorization.
- The People appealed under CA.R. 4.1 and §16-12-102(2), challenging the suppression order as an impermissible Fourth Amendment inventory/search issue.
- Vaughn challenged the admissibility of evidence obtained from the vehicle during a warrantless search following arrest.
- The APD policy requires towing, inventory, and impoundment after an arrest, with glove box and other items documented prior to impoundment.
- The Colorado Supreme Court held the evidence was seized via a valid inventory search under a standardized policy and reversed the suppression order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop was constitutionally justified by reasonable suspicion | People had reasonable suspicion due to observed traffic violation and missing vehicle record | Vaughn contends stop was invalid or unsupported by reasonable suspicion | Yes; stop was constitutionally permissible |
| Whether arrest and subsequent inventory search were valid | People argues probable cause supported arrest and inventory search | Vaughn argues lack of probable cause for arrest/invalid inventory search | Yes; arrest supported by probable cause and inventory search conducted under policy |
| Whether the inventory search scope complied with policy | People asserts policy authorized comprehensive inventory including glove box | Vaughn argues scope exceeded permissible limits | Yes; search conducted pursuant to standardized APD policy and within permissible scope |
Key Cases Cited
- People v. Hill, 929 P.2d 735 (Colo. 1996) (automobile exception requires probable cause for noninventory searches)
- Colorado v. Bertine, 479 U.S. 367 (1987) (inventory searches are reasonable when pursuant to policy and conducted for caretaking purposes)
- Pineda v. People, 230 P.3d 1181 (Colo. 2010) (inventory searches reasonable under standardized policy)
- Vissarriagas, 2012 CO 48 (Colo. 2012) (reasonable suspicion sufficient for traffic stop; subjective motives irrelevant)