State of Washington v. Joel Matthew Groves
33874-6
| Wash. Ct. App. | Jan 26, 2017Background
- Joel Groves was stopped for speeding while riding a motorcycle; the trooper suspected the bike might be stolen but lacked probable cause to confirm it.
- Groves was not arrested but was not allowed to ride away because he lacked a motorcycle endorsement.
- The trooper impounded the motorcycle based on a Washington State Patrol policy that mandated impoundment of motorcycles operated without an endorsement.
- During an inventory search of the impounded motorcycle, the trooper removed the seat and opened two zippered cases, finding drugs and related evidence.
- Groves moved to suppress the evidence; the trial court denied the motion, he was convicted, and he appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of impound when based on a mandatory agency policy | Groves: impound was invalid because RCW and precedent require individualized discretion, not mandatory policies | State: impound lawful under agency policy to secure vehicle and because Groves lacked endorsement | Court: Impound unconstitutional under state law; agency policy removed required individual discretion (In re Impoundment of Chevrolet Truck) |
| Opening closed containers during inventory search | Groves: opening zippered cases required consent or exigent circumstances; none existed | State: inventory search permitted and justified to locate ownership documents and secure vehicle | Court: Opening closed containers was unlawful without consent or exigency (State v. Houser) |
| Validity of inventory procedure | Groves: inventory was improper because it was not conducted under standardized criteria/procedures | State: inventory was a routine search incident to impound and therefore valid | Court: Inventory violated Fourth Amendment principles where standardized criteria were lacking (Florida v. Wells); search invalid |
Key Cases Cited
- In re Impoundment of Chevrolet Truck, 148 Wn.2d 145 (2002) (agency must exercise individualized discretion before impoundment)
- State v. Houser, 95 Wn.2d 143 (1980) (police may not open closed containers during inventory absent consent or exigent circumstances)
- Florida v. Wells, 495 U.S. 1 (1990) (inventory searches must follow standardized criteria or established procedures to prevent arbitrary intrusion)