State of Arizona v. Matthew Thomas Snyder, 382 P.3d 109

Background

In Jan. 2013 loss-prevention officer detained Matthew Snyder after observing conduct he believed to be shoplifting; Snyder had a backpack in a nearby employee room and sustained a broken kneecap during the detention.
Tucson PD Officer Ives arrived ~10 minutes later, advised Snyder of Miranda rights, questioned him while Snyder remained in handcuffs, then decided to arrest him for shoplifting.
Before replacing the loss-prevention handcuffs, Ives instructed Officer Dave to search Snyder’s backpack (located in a separate employee room near the doorway).
The search produced an antique flintlock pistol, a .22 handgun, methamphetamine, and ammunition.
Snyder moved to suppress the backpack evidence; the trial court denied the motion, finding the search inevitable as part of booking/inventory.
On appeal the court considered whether (1) Snyder was under arrest, (2) the backpack was within his immediate control to justify a search incident to arrest, and (3) the inevitable-discovery/inventory exception applied.

Issues

Issue	State's Argument	Snyder's Argument	Held
Was Snyder under arrest when the backpack was searched?	He was effectively under arrest: detained, handcuffed, read Miranda, and then re-cuffed by police.	He was initially detained by loss-prevention, not formally arrested by police.	Held: Objectively a reasonable person would believe arrest had occurred. Arrest present.
Was the backpack searchable as incident to arrest?	Backpack was near the security-room entrance and could have been accessed quickly; search permitted for officer safety/evidence preservation.	Snyder was handcuffed, separated from the pack in another room, and injured; no possibility of reaching it.	Held: Search-incident-to-arrest inapplicable; pack was not within Snyder’s immediate control.
Could the evidence be admitted under inevitable discovery/inventory-search doctrine?	Trial court found search inevitable as part of booking/inventory procedures; State relied on booking and transport policies.	Inevitable discovery inapplicable because arrest/book-inventory was discretionary (likely misdemeanor), Snyder was transported to a hospital, and no formal practice ensured an immediate inventory.	Held: Inevitable-discovery/inventory did not justify the search on this record; not inevitable.
Should suppression be reversed and convictions vacated?	N/A (State unsuccessfully defended search).	Evidence was product of unconstitutional search; suppression required.	Held: Trial court erred; suppression should have been granted; convictions and sentences vacated and remanded.

Key Cases Cited

Arizona v. Gant, 556 U.S. 332 (2009) (search-incident-to-arrest limited to areas within arrestee's immediate control)
Chimel v. California, 395 U.S. 752 (1969) (area "within immediate control" standard for searches incident to arrest)
United States v. Chadwick, 433 U.S. 1 (1977) (once property is removed from arrestee's exclusive control, search incident to arrest generally unavailable)
Illinois v. Lafayette, 462 U.S. 640 (1983) (booking/inventory searches are a recognized exception to the warrant requirement when properly conducted)
Florida v. Wells, 495 U.S. 1 (1990) (inventory policies must not be a pretext for general evidence searches)
State v. Calabrese, 157 Ariz. 189 (App. 1988) (accelerated/early booking searches cannot justify pre-booking warrantless searches; inevitable-discovery not met for discretionary misdemeanors)
State v. Noles, 113 Ariz. 78 (1976) (search incident to arrest valid where property was within defendant's immediate control at arrest)
State v. Davolt, 207 Ariz. 191 (2004) (articulates Arizona application of inevitable-discovery doctrine)