State v. Rohde, 839 N.W.2d 758

Undercover Blaine officers developed a drug-trafficking lead about a Monte Carlo with multiple occupants and identified Rohde as the vehicle’s owner; Rohde’s registration and her driver’s license were revoked, and Rohde had a prior arrest involving drugs.
Officer Champagne stopped Rohde for a signaling violation and because the vehicle reportedly lacked insurance; Rohde stated the vehicle was uninsured.
Rohde was not free to leave at the scene and was placed in a squad car while the officers prepared to impound the vehicle for the revocation and lack of insurance.
Officer Koch conducted an inventory search of the impounded vehicle and opened a purse containing a bag-like item later suspected to be methamphetamine and two glass pipes.
Rohde was charged with fifth-degree controlled-substance crime and possessing drug paraphernalia; the district court denied suppression and Rohde was convicted after a stipulated-facts trial.
The district court held the impoundment lawful and the inventory search not pretextual, leading to affirmed conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the impoundment and inventory search authorized by law?	Rohde argues no lawful basis to impound or search.	State argues revoked registration/plates and lack of insurance justify impoundment and inventory search as caretaking.	Yes; impoundment lawful and inventory search proper.
Was the inventory search conducted in accordance with standard procedures and not pretextual?	Rohde contends search was pretextual to find drugs.	State contends search followed standard procedures and pursued inventory purposes.	Yes; search was consistent with procedures and not pretextual.

State v. Munson, 594 N.W.2d 128 (Minn. 1999) (inventory searches as reasonable with proper impoundment)
Colorado v. Bertine, 479 U.S. 367 (U.S. 1987) (inventory searches are a recognized exception to the warrant requirement)
State v. Holmes, 569 N.W.2d 181 (Minn. 1997) (inventory searches require standard procedures)
State v. Gauster, 752 N.W.2d 496 (Minn. 2008) (police caretaking; ability to arrange tow affects impoundment validity)
State v. Ture, 632 N.W.2d 621 (Minn. 2001) (inventory search valid if not solely for investigation)
State v. Goodrich, 256 N.W.2d 506 (Minn. 1977) (impoundment predicates inventory reasonableness)
State v. Othoudt, 482 N.W.2d 218 (Minn. 1992) (standard for reviewing suppression orders)
State v. Jordan, 742 N.W.2d 149 (Minn. 2007) (facts reviewed independently when no dispute)
State v. Everett, 472 N.W.2d 864 (Minn. 1991) (lawfulness of search supports upholding arrest/search)