United States v. Artak Moskovyan, 618 F. App'x 331

Artak Moskovyan pleaded guilty to conspiracy to commit access device fraud and aggravated identity theft.
He challenged the district court’s denial of motions to suppress evidence obtained after a warrantless car inventory search and a subsequent home search.
Officers impounded Moskovyan’s luxury sedan in a high-traffic, unfenced lot due to risk of theft, vandalism, and illegal parking, with Moskovyan absent.
The police performed an inventory search of the vehicle following impoundment, consistent with local procedure and without improper investigative motive.
A search warrant for Moskovyan’s residence was supported by an affidavit later framed in an extinguished Franks context, including a typographical arrest-date error.
The district court addressable issues included probable cause for the home search and the scope of Franks during the suppression hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the car impoundment valid under community caretaking?	Moskovyan	Moskovyan	Affirmed; impoundment justified.
Was the vehicle inventory search valid under standard procedure?	Moskovyan	Moskovyan	Affirmed; inventory search valid.
Did the Franks limitations apply to the home search affidavit and other issues require relief?	Moskovyan	Moskovyan	Affirmed; Franks hearing limited to one issue.
Was there probable cause for the nighttime search of Moskovyan’s residence despite a date typographical error?	Moskovyan	Moskovyan	Affirmed; error did not render probable cause stale.

Miranda v. City of Cornelius, 429 F.3d 858 (9th Cir. 2005) (community caretaking supports impoundment when risk exists)
Ramirez v. City of Buena Park, 560 F.3d 1012 (9th Cir. 2009) (vehicle risk factors for impoundment)
Hallstrom v. City of Garden City, 991 F.2d 1473 (9th Cir. 1993) (impoundment implications for illegal parking)
United States v. Cervantes, 703 F.3d 1135 (9th Cir. 2012) (inventory search adherence to procedure; no bad faith shown)
United States v. Jensen, 425 F.3d 698 (9th Cir. 2005) (standard for vehicle impoundment authority)
South Dakota v. Opperman, 428 U.S. 364 (U.S. 1976) (general police inventory search rationale)
United States v. Bertine, 479 U.S. 367 (1987) (good faith requirement in inventory searches)
United States v. Bowhay, 992 F.2d 229 (9th Cir. 1993) (inventory search allowed despite investigatory motive)
United States v. Chavez-Miranda, 306 F.3d 973 (9th Cir. 2002) (nexus between arrest evidence and home search)
United States v. Hill, 459 F.3d 966 (9th Cir. 2006) (fair probability for further evidence from arrest scene)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances probable cause standard)
United States v. Crews, 502 F.3d 1130 (9th Cir. 2007) (good-faith exception to exclusionary rule)
United States v. Leon, 468 U.S. 897 (1984) (good-faith reliance on warrant not invalidating evidence)
Franks v. Delaware, 438 U.S. 154 (1978) (Franks hearing procedure for false anest statements in affidavits)