State v. Paynter
170 A.3d 891
Md. Ct. Spec. App.2017Background
- On Dec. 13, 2016, police stopped Daniel Paynter for speeding; checks showed his license was suspended and the vehicle had a motor-vehicle “pick-up order” for suspended tags, so officers arranged for tow/impound.
- Laurel Police officers performed an inventory of the impounded car pursuant to a seven-page Department General Order; tow report listed a phone in the console and seven Mac computers in the trunk.
- Body-camera footage of the inventory (admitted at the suppression hearing) showed additional items in the trunk (spare tire, jack, jumper cables, three pairs of tennis shoes) not individually listed on the tow report; during the inventory police discovered 51 grams of marijuana.
- Paynter moved to suppress the evidence; the trial court granted the motion, reasoning that the inventory was invalid because it failed to list “everything.”
- The State appealed the suppression order; the Court of Special Appeals reviewed de novo whether the inventory/impound met Fourth Amendment standards and reversed the suppression order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether impoundment/inventory was lawful | Paynter: impound/search was pretext for investigation and thus invalid | State: car lawfully impounded (suspended tags/pick-up order); inventory caretaking function | Held: impoundment lawful; inventory exception applies when vehicle lawfully in custody |
| Requirement of standardized police policy | Paynter: police must strictly follow procedures and listing completeness shows good faith; failure to list all items invalidates inventory | State: department had a written General Order requiring inventories; policy requirement satisfied | Held: standardized policy existed and was produced; requirement satisfied |
| Completeness of inventory list (omitted items) | Paynter: unlisted trunk items show flawed inventory and retrospective invalidation of search | State: listing is separate from the act of searching; omission of insignificant items does not invalidate search | Held: later listing imperfections do not retroactively invalidate the prior valid inventory search; listing need not itemize every insignificant object |
| Mixed motives / officer suspicion (10–0 possibly armed) | Paynter: receiving alert that driver might be armed shows investigatory motive, turning inventory into a ruse | State: expectation of finding evidence does not vitiate bona fide inventory conducted under standardized procedures | Held: mixed motives permissible; expectation of finding evidence does not automatically render inventory invalid |
Key Cases Cited
- South Dakota v. Opperman, 428 U.S. 364 (inventory of impounded vehicle as caretaking, constitutional under Fourth Amendment)
- Illinois v. Lafayette, 462 U.S. 640 (inventory procedures need not use the least intrusive means; focus on reasonableness)
- Colorado v. Bertine, 479 U.S. 367 (inventory searches valid under standardized procedures even if conducted imperfectly)
- Florida v. Wells, 495 U.S. 1 (opening closed containers during inventory requires an existing departmental policy/guidance)
- Briscoe v. State, 422 Md. 384 (suppression where State presented no evidence of a standardized inventory policy)