State v. Tyler, 302 P.3d 165

Traffic stop for speeding; both driver and passenger had suspended licenses; vehicle impounded for roadway safety and to preserve property; officers conducted an inventory search during impoundment and found methamphetamine; defendant Tyler was convicted of meth possession and license suspension violation; Tyler moved to suppress arguing pretext and lack of owner consent; trial court denied suppression requests; Court of Appeals affirmed; majority held inventory searches of lawfully impounded vehicles do not require consent under article I, section 7; dissent argued pretext showing inventory purpose was investigative.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether inventory search of impounded vehicle requires owner consent	Tyler argues consent is required and search was pretextual	State argues inventory search is valid without consent when impoundment is lawful	Consent not required for lawful inventory search under article I, §7
Whether impoundment was reasonable given alternatives	Tyler contends impoundment was unnecessary or pretextual	Anglin reasonably impounded to protect public safety and vehicle contents	Impoundment proper; reasonable alternatives were considered but not viable
Whether denial to reopen suppression hearing was an abuse of discretion	Tyler argues e-mail shows predisposition to pretext	Trial court properly denied reopening; e-mail not probative of pretext	No abuse of discretion in denying motion to reopen
Whether admitting inventory-search evidence violates article I, §7 due to pretext	Search was pretextual to perform investigative search	Search conducted in good faith to inventory impounded vehicle	No pretext; inventory search upheld; no consent prerequisite required
Whether locked containers require consent for inventory searches	Consent should be required to search locked trunks/containers	Consistent with limited inventory purposes; manifest necessity governs locked containers	Consent not generally required; locked containers require consent only where manifest necessity exists

State v. Snapp, 174 Wn.2d 177 (2012) (inventory search and privacy in vehicles under WA Const.)
State v. Afana, 169 Wn.2d 169 (2010) (privacy and vehicle inventory search limits under WA Const.)
State v. Valdez, 167 Wn.2d 761 (2009) (warrantless inventories; authority of law under WA Const.)
State v. Houser, 95 Wn.2d 143 (1980) (inventory search limits; balance of impoundment reasons and good faith)
State v. White, 135 Wn.2d 761 (1998) (inventory search scope and trunks/containers; manifest necessity)