St. Clair v. State
2011 Tex. App. LEXIS 2820
| Tex. App. | 2011Background
- Officer stopped St. Clair for a nonworking tag light; discovered an outstanding arrest warrant.
- St. Clair was arrested and was the sole occupant of the vehicle.
- Policy required a vehicle inventory after an arrest to protect property and liability.
- Officer conducted what he believed to be an inventory search and found St. Clair's purse inside the vehicle.
- Inside the purse, the officer found a wallet with $88 and a small quantity of a controlled substance.
- The trial court denied suppression; defense challenge focused on the inventory search.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the vehicle inventory search was lawful | St. Clair argues the search was improper. | State argues inventory search authorized by policy and impoundment needs. | Inventory search upheld; search proper. |
Key Cases Cited
- Daniels v. State, 600 S.W.2d 813 (Tex.Crim.App.1980) (inventory search may be used to protect property when impounding a vehicle)
- Foster v. State, 874 S.W.2d 286 (Tex.App.-Fort Worth 1994) (preservation of error requires grounds asserted at trial to comport with appeal)
- Mayberry v. State, 830 S.W.2d 176 (Tex.App.-Dallas 1992) (police not required to investigate alternatives to impoundment absent evidence)
- Richards v. State, 150 S.W.3d 762 (Tex.App.-Houston [14th Dist.] 2004) (lack of owner identity affects obligations to move or release vehicle)