State v. Ramos, 536 P.3d 876

Deputy Katseanes found an unlocked car at a public boat launch with trunk and front windows open; dispatch identified the vehicle as registered to April Ramos, who had an outstanding felony warrant.
Katseanes searched the trunk and back seat while waiting for backup and a tracking/drug canine; multiple officers and a canine thereafter searched the surrounding area but did not locate Ramos.
Officers believed the car likely contained drugs; a canine sniff of the car’s exterior did not alert. Officers discussed that the car was parked in an accessible parking spot and called for a tow.
The vehicle was impounded and an inventory search prior to towing uncovered methamphetamine and paraphernalia; Ramos was charged and moved to suppress the evidence.
The district court denied suppression under the inventory exception, finding the tow objectively reasonable (including that the car occupied an accessible space); the Court of Appeals affirmed; the Idaho Supreme Court granted review, vacated, and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the impoundment/inventory was a pretext to search for evidence	Ramos: officers intended to search for evidence; tow was a ruse and no warrant was sought	State: impoundment was lawful under community caretaking/inventory doctrine and vehicle was illegally parked	Court: reversed and remanded; adopted a "primary purpose" test — impoundment unconstitutional if primary purpose was investigatory; remand to assess subjective intent and reasonableness
Whether risk of theft/damage justifies impoundment under community caretaking	Ramos: anticipated theft/damage is insufficient to justify towing	State: protecting the vehicle from theft/vandalism supports impoundment	Court: declined to expand Opperman to allow towing solely to prevent possible theft/damage; such concerns are irrelevant to Fourth Amendment reasonableness analysis
Effect of unlawful impoundment on inventory exception	Ramos: unlawful impoundment taints any subsequent inventory and evidence must be suppressed	State: if impoundment is lawful and procedures followed, inventory exception applies	Court: if impoundment is unconstitutional, the inventory is tainted; burden remains on State to prove impoundment lawful and not pretextual
Preservation of pretext argument on appeal	Ramos: preserved pretext argument at suppression hearing	State: argued Ramos failed to preserve the issue	Court: held Ramos preserved the claim; appellate refinement permitted

South Dakota v. Opperman, 428 U.S. 364 (1976) (upholding inventory searches following lawful impoundments as community caretaking)
Colorado v. Bertine, 479 U.S. 367 (1987) (inventory searches are lawful when following standardized procedures and not a pretext)
Florida v. Wells, 495 U.S. 1 (1990) (inventory searches must not be a ruse for general rummaging)
Cady v. Dombrowski, 413 U.S. 433 (1973) (community caretaking justification for vehicle searches in certain contexts)
State v. Weaver, 127 Idaho 288 (1995) (Idaho law recognizing limits on inventory searches and impoundments)
State v. Hoskins, 165 Idaho 217 (2019) (burden shifts to State to justify warrantless searches)
United States v. Grey, 959 F.3d 1166 (9th Cir. 2020) (discussing impermissible pretextual impoundments and primary-purpose analysis)
United States v. Johnson, 889 F.3d 1120 (9th Cir. 2018) (same)