United States v. Henry Williams
2015 U.S. App. LEXIS 1804
| 8th Cir. | 2015Background
- On Dec. 19, 2012, Officer Loftis responded to a reported theft at GameStop and pursued a Cadillac; driver Henry Williams was wearing a Pittsburgh Steelers jacket matching the suspect description.
- After stopping the car, officers ordered Williams out; a partially open rear window revealed bubble wrap in the center console; officers removed a bubble-wrapped stolen iPad.
- Williams was arrested after resisting and physically grabbing the iPad; the store manager later identified him as the thief.
- Under Raytown police tow policy, officers decided to impound the vehicle after the custodial arrest and performed an inventory of the car’s contents.
- During the inventory, officers discovered a duffel in the trunk containing a loaded, stolen AK-47; Williams later admitted stealing the firearm after Miranda warnings.
- Williams moved to suppress the rifle, arguing the warrantless vehicle search was unlawful because the impoundment was improper and the inventory deviated from policy; the district court denied the motion and Williams appealed.
Issues
| Issue | Williams' Argument | Government's Argument | Held |
|---|---|---|---|
| Whether impoundment was unlawful pretext to search | Impoundment was unnecessary; car could have been left on street or released; thus search invalid | Officer lawfully exercised discretionary, standardized criteria to impound given high-crime area, bond issue, and inability to secure release while arrestee handcuffed | Court: Impoundment lawful; officer’s reasons tied to caretaking purposes, not pretext |
| Whether inventory search was invalid due to failure to list all loose items | Failure to inventory all low-value loose items violated policy and shows pretext | Minor deviations do not render an inventory unreasonable absent evidence of pretext | Court: Minor deviation insufficient; Williams did not show omitted items or improper motive; search valid |
Key Cases Cited
- United States v. Rehkop, 96 F.3d 301 (8th Cir.) (scope and validity of warrantless inventory searches of impounded vehicles)
- United States v. Mayfield, 161 F.3d 1143 (8th Cir.) (deviation from inventory procedures does not automatically render search unreasonable)
- United States v. Stephenson, 924 F.2d 753 (8th Cir.) (standard of review for suppression rulings: factual findings clearly erroneous; legal conclusions de novo)
- United States v. Arrocha, 713 F.3d 1159 (8th Cir.) (officer not required to allow arrestee to arrange pick-up to avoid impoundment)
- United States v. Petty, 367 F.3d 1009 (8th Cir.) (officer discretion in impoundment must be based on legitimate caretaking concerns)
- Colorado v. Bertine, 479 U.S. 367 (U.S.) (inventory searches permissible under Fourth Amendment when conducted under standardized procedures)
- Whren v. United States, 517 U.S. 806 (U.S.) (departure from procedures alone does not prove pretext)