State v. Baker, 111915

Baker was arrested in a public retail store in Lawrence on outstanding warrants; he had a blue backpack with him which officers seized for safekeeping.
Officers Halsted searched Baker’s backpack at the scene and found needles in a Nintendo game case, then searched a bag inside the backpack in an evidence room and found methamphetamine.
Baker moved to suppress the warrantless backpack search as unconstitutional and argued the evidence would not have been inevitably discovered through an inventory search.
The district court denied suppression, finding no probable cause but that the evidence would have been inevitably discovered via an inventory search; the court relied on a claimed policy to search arrestee bags.
The Court of Appeals affirmed the conviction; the Kansas Supreme Court reversed and remanded, holding no proven standardized inventory routine; the inevitable-discovery claim failed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the backpack seizure reasonable under the totality of circumstances?	Baker argues the seizure was unlawful custody.	Baker contends no lawful custody/standards justified seizure.	Yes; seizure reasonable under totality of circumstances.
Did the State prove inevitable discovery via a standardized inventory procedure?	State lacked evidence of a standardized criteria or routine.	State relied on jail policy to inventory search bags.	No; no proven standardized procedure; no inevitable discovery.
Must inventory searches be governed by standardized criteria or established routines for containers?	Baker argues no established policy; policy lacking.	State claims routine would have opened containers.	Wells rule requires standardized criteria or routine; not shown here.

Lafayette, 462 U.S. 640 (U.S. Supreme Court 1983) (inventory searches serve legitimate governmental interests and protect property)
Bertine, 479 U.S. 367 (U.S. Supreme Court 1987) (inventory procedures protect property and guard police from danger)
Wells, 495 U.S. 1 (U.S. Supreme Court 1990) (standardized criteria required for container openings during inventory searches)
Perea, 986 F.2d 633 (2d Cir. 1993) (inventory/opening containers per established procedures permissible)