People v. Wallace, 15 Cal. App. 5th 82

In March 2015 Wallace was charged with possession of a baton (Pen. Code § 22210); he moved to suppress the baton found in his car.
Officer Ambrose responded to a traffic stop where Wallace was removed, handcuffed, and placed in Ambrose’s patrol car; Ambrose then searched Wallace’s vehicle and found a 24-inch wooden baton.
Ambrose testified the department had a policy to tow and inventory unattended vehicles and to fill out a CHP-180 form when towing, but he did not say he or anyone decided to tow in this case, did not complete a CHP-180, and left the scene before any towing decision was known.
The magistrate and trial court denied Wallace’s suppression motion, concluding Ambrose’s search was an inventory/search incident to custody and/or community caretaking; Wallace pled no contest and reserved the suppression issue for appeal.
On appeal the People did not argue the search was a valid inventory search but raised inevitable discovery — that the baton would have been found during an inventory after impoundment.
The Court of Appeal reversed: it held there was no substantial evidence Ambrose conducted an inventory search under standardized policy and no substantial evidence the baton inevitably would have been discovered by lawful impound/inventory procedures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Ambrose’s warrantless search a valid inventory search?	The People: Ambrose acted pursuant to department policy to tow and inventory unattended/unlicensed vehicles.	Wallace: No substantial evidence the search followed standardized inventory procedures or that towing was decided.	No — insufficient evidence that a policy-compliant inventory occurred; search not shown to fit the inventory exception.
Could the baton be admitted under the inevitable discovery doctrine?	The People: Vehicle would have been impounded/inventoried (no one to take custody) and impound personnel would have found the baton.	Wallace: Record silent on any towing decision, who decided it, location of vehicle, or whether CHP-180/inventory occurred — speculative.	No — inevitable discovery not proven; too speculative that lawful impound/inventory would have occurred and uncovered the baton.
Did the suppression error require reversal of conviction entered after plea?	The People: (implicit) suppression denial need not undo plea if harmless or lawful discovery independent.	Wallace: The denial was prejudicial because he pled after the adverse ruling.	Reversal: Error prejudicial; defendant may withdraw no-contest plea and trial court must grant suppression motion on remand.

South Dakota v. Opperman, 428 U.S. 364 (inventory searches in impoundment/community caretaking context)
Florida v. Wells, 495 U.S. 1 (inventory searches must follow standardized criteria to avoid pretext)
Colorado v. Bertine, 479 U.S. 367 (policies governing inventories required; discretion must be structured)
Nix v. Williams, 467 U.S. 431 (inevitable discovery exception to exclusionary rule)
People v. Williams, 20 Cal.4th 119 (California discussion of inventory-search limits and need for preexisting policy)