276 P.3d 740
Idaho Ct. App.2012Background
- Stewart was stopped for failure to signal; she was uninsured and driving on a suspended license.
- An officer arrested Stewart custodially and arranged for a tow to impound the vehicle.
- Before the tow arrived, the officer conducted an inventory search and found marijuana and methamphetamine in a tin.
- Stewart admitted the drugs were hers but denied using methamphetamine, claiming intent to sell.
- Stewart moved to suppress the stop, impoundment, and inventory search; the district court denied the motion.
- Stewart pled guilty to methamphetamine possession with intent to deliver and driving without privileges, with the marijuana charge dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the impoundment and inventory search complied with the Fourth Amendment | Stewart | Stewart | Yes; impoundment and inventory search were reasonable under Fourth Amendment. |
| Whether the impoundment was reasonable given the vehicle’s location and uninsured status | Stewart | Stewart | Yes; vehicle in public gas-station lot, uninsured, high risk of theft/damage; impoundment reasonable. |
| Whether the officer needed Watch Commander approval for impoundment | Stewart | Stewart | No; standing approval sufficed and failure to obtain individual approval did not render search unreasonable. |
| Whether noncompliance with department policy renders the inventory search per se unreasonable | Stewart | Stewart | No; policy noncompliance does not automatically invalidate an inventory search. |
Key Cases Cited
- State v. Weaver, 127 Idaho 288 (1995) (inventory searches may be valid when supported by reasonable grounds; general rule on reasonable searches)
- State v. Foster, 127 Idaho 723 (1995) (impoundment must be reasonable; taints inventory search if not)
- Florida v. Wells, 495 U.S. 1 (1990) (inventory searches are not per se invalid when not a pretext; must have criteria)
- South Dakota v. Opperman, 428 U.S. 364 (1976) (inventory search as legitimate police function to protect property and safety)
- Illinois v. Lafayette, 462 U.S. 640 (1983) (limits and purposes of inventory searches)
- Cady v. Dombrowski, 413 U.S. 433 (1973) (reasonableness framework for searches; particular facts matter)
- Owen, 143 Idaho 274 (2006) (inventory search standards in Idaho; not a general rummaging)