United States v. Craig Snoddy, 976 F.3d 630

Around 1:00 a.m., Trooper Malone stopped Craig Snoddy for speeding, learned of outstanding Georgia warrants (including drug-related), and arrested Snoddy, the car’s sole occupant.
Malone twice asked for consent to search the vehicle; Snoddy refused. Malone then repeatedly sought consent over ~12 minutes; still refused.
Malone called for a tow and, pursuant to Tennessee DPS General Order 513 (requiring an inventory on custodial arrests before towing), began an inventory and found ~1 lb methamphetamine, two handguns, and scales.
Snoddy moved to suppress the seized evidence, claiming the impound/inventory was a pretext for a warrantless investigative search in violation of the Fourth Amendment.
The magistrate judge and district court denied the motion, finding the inventory lawful under department policy and not a pretext; Snoddy pleaded guilty while reserving the suppression appeal.
The Sixth Circuit affirmed, holding the district court did not clearly err in finding the inventory was not pretextual and was objectively justifiable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the inventory search was a pretext for an investigative, warrantless search under the Fourth Amendment	Snoddy: Malone’s repeated requests for consent, statements he expected to find drugs, and timing of calling the tow show the inventory was a pretext to search for contraband	Government: Impoundment and inventory were objectively justified (sole occupant, nighttime roadside risk), and the search followed published DMV policy requiring inventory on custodial arrest	Court: Denied suppression; no clear error. Officer’s subjective intent irrelevant where impoundment and inventory were objectively justified and conducted under standard policy
Whether officer had an obligation to contact vehicle owner (girlfriend) instead of impounding	Snoddy: Officer could have contacted girlfriend to pick up the car, making impoundment unnecessary and inventory pretextual	Government: Even if owner could have picked it up, impoundment was within officer’s discretion under precedent	Court: Rejected as meritless; no record showing Snoddy requested contact, and decision to impound was discretionary and lawful

Arizona v. Gant, 556 U.S. 332 (2009) (warrantless vehicle searches are per se unreasonable except recognized exceptions)
Whren v. United States, 517 U.S. 806 (1996) (officer’s subjective intent does not invalidate objectively justified Fourth Amendment seizures)
Colorado v. Bertine, 479 U.S. 367 (1987) (inventory searches are a well-defined exception to the warrant requirement)
South Dakota v. Opperman, 428 U.S. 364 (1976) (inventory searches of impounded vehicles are permissible caretaking procedures)
Florida v. Wells, 495 U.S. 1 (1990) (inventory searches must follow standardized procedures and not be a pretext for investigation)
United States v. Smith, 510 F.3d 641 (6th Cir. 2007) (officer suspicion of contraband alone does not invalidate a proper inventory search)
United States v. Hockenberry, 730 F.3d 645 (6th Cir. 2013) (district court not clearly erroneous in finding inventory non-pretextual despite suggestive officer conduct)
United States v. Kimes, 246 F.3d 800 (6th Cir. 2001) (impoundment decisions must be based on standard criteria and not on suspicion of evidence; objective justification controls)
United States v. Jackson, 682 F.3d 448 (6th Cir. 2012) (vehicle lawfully seized when lawfully impounded, making it subject to inventory search)