State of Minnesota v. Erica Ann Rohde, 852 N.W.2d 260

Officer Koch, in plain clothes in an unmarked car, observed a Monte Carlo leave a suspected drug house and learned its registration and driver’s license were revoked and that the registered owner was Erica Rohde.
Officer Champagne (uniformed, marked car) stopped the Monte Carlo for a signaling violation; the vehicle was lawfully parked at the curb and not blocking traffic or creating a safety issue.
Champagne learned the car was uninsured and, citing department policy, decided to tow and impound the vehicle; Rohde was not taken to jail and was allowed to call her mother to arrange a ride.
An inventory search required by department policy was performed; Officer Koch searched a purse in the car and found methamphetamine and pipes.
Rohde was charged with fifth-degree drug possession and possession of drug paraphernalia; she moved to suppress the evidence as the product of an unconstitutional search.
The district court denied suppression; the court of appeals affirmed. The Minnesota Supreme Court granted review and reversed, holding the impoundment (and thus the inventory search) unreasonable under the Fourth Amendment.

Issue	Rohde's Argument	State's Argument	Held
Whether impoundment of a lawfully parked, uninsured vehicle was reasonable under the Fourth Amendment	Impoundment was unreasonable because Rohde was not arrested, retained control of the vehicle, and the car posed no safety or traffic threat	Impoundment was justified by department policy and because registration/license revoked and vehicle uninsured	Court held impoundment unreasonable: driver not arrested, vehicle not a safety/traffic threat, and police had no caretaking necessity
Whether inventory search exception applies when impoundment is claimed	Search was pretextual and cannot be justified because impoundment itself was unreasonable	Inventory-search exception justified the search if impoundment complied with standardized policy	Court held inventory search unconstitutional because it flowed from an unreasonable impoundment
Role of state statutes/policy in justifying impoundment	Statutes/policy cannot validate an otherwise unreasonable Fourth Amendment seizure	State relied on statutes and department policy as authorization for impoundment	Court: statutory authorization is not dispositive; constitutional reasonableness is the controlling inquiry

Mapp v. Ohio, 367 U.S. 643 (1961) (evidence from unreasonable searches inadmissible)
Katz v. United States, 389 U.S. 347 (1967) (warrantless searches presumptively unreasonable)
South Dakota v. Opperman, 428 U.S. 364 (1976) (police community-caretaking authority to remove vehicles that impede traffic or threaten safety)
Colorado v. Bertine, 479 U.S. 367 (1987) (inventory searches are a warrant exception when incident to lawful impoundment)
Cooper v. California, 386 U.S. 58 (1967) (state law authorization does not resolve Fourth Amendment reasonableness)
State v. Gauster, 752 N.W.2d 496 (Minn. 2008) (threshold inquiry: whether impoundment was proper under standardized criteria)
State v. Goodrich, 256 N.W.2d 506 (Minn. 1977) (police may impound to protect vehicle/property and police from claims)
State v. Ture, 632 N.W.2d 621 (Minn. 2001) (de novo review of legal question whether suppression required)
State v. Robb, 605 N.W.2d 96 (Minn. 2000) (impoundment unreasonable when alternative custodian available)