United States v. Darryl Seay, 944 F.3d 220

Police responded to a hotel eviction of Devin Bracey and encountered Darryl Seay; both exited the room and Seay carried a clear plastic bag.
Officers searched the hotel room and found ammunition and drug paraphernalia; they determined they had probable cause to arrest Bracey.
While Seay was being interviewed, Officer Lucy searched Bracey’s belongings; Bracey twice identified the clear plastic bag as “our stuff.”
Officer Lucy opened the bag and found a handgun wrapped in a jacket; Seay was charged under 18 U.S.C. § 922(g)(1).
Seay moved to suppress the firearm and post-arrest statements; the district court suppressed the statements but denied suppression of the firearm, concluding the inevitable discovery doctrine applied.
Seay appealed the denial of suppression; the Fourth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the firearm must be suppressed as the fruit of an unconstitutional search	Seay: the search of the plastic bag was unlawful and evidence should be suppressed	Government: officers had probable cause to arrest Bracey and would have inevitably discovered the gun via an inventory of her property	Court: affirmed denial—inevitable discovery applies; firearm admissible
Whether the government proved the inventory search met the standardized-criteria requirement (no improper discretion)	Seay: testimony showed officer discretion in inventory procedure, so policy was not sufficiently standardized	Government: testimony established standard practice; limited discretion is permissible and aligned with inventory purposes	Court: discretion here was limited and permissible; testimony sufficed to show standardized practice
Whether the bag belonged to Seay (non-arrestee) so inventory would not apply	Seay: he carried the bag and ownership meant police could not inventory it as Bracey’s property	Government: Bracey twice identified the bag as “our stuff,” and officers would have inventoried her belongings or documented release to Seay	Court: district court did not clearly err — bag would have been inventoried and the gun inevitably discovered

Nix v. Williams, 467 U.S. 431 (inevitable discovery doctrine)
Utah v. Strieff, 136 S. Ct. 2056 (exceptions to exclusionary rule)
United States v. Bullette, 854 F.3d 261 (4th Cir. 2017) (inevitable discovery analysis)
United States v. Matthews, 591 F.3d 230 (4th Cir. 2009) (inventory-search standardized-criteria requirement)
Colorado v. Bertine, 479 U.S. 367 (inventory searches as exception to warrant requirement)
Florida v. Wells, 495 U.S. 1 (inventory policy must limit officer discretion)
United States v. Banks, 482 F.3d 733 (limited discretion in inventory procedure may be permissible)