United States v. Trujillo, 418 F.Supp.3d 867

Shortly after 2:40 a.m., Bernalillo County Deputy Mitchell Skroch pursued a Ford Mustang for speeding and a suspected failure to yield to emergency lights; the vehicle stopped in the entranceway to a gated community.
Deputy Skroch conducted a felony stop, handcuffed and arrested Gabriel Trujillo, and—pursuant to Bernalillo County Sheriff’s Department policy that directs towing upon an arrest when no registered owner is present—decided immediately to impound the Mustang.
The deputy made the towing decision before visually clearing the vehicle and before observing firearms; he did not ask Trujillo for consent or attempt to contact any third party or private tow as an alternative.
An inventory search after impoundment produced a locked backpack; after opening it, deputies recovered methamphetamine, a 1911 handgun, and bundles of currency.
Trujillo was indicted on drug- and gun-related federal charges. He moved to suppress the evidence from the inventory search, arguing the impoundment was unconstitutional under Sanders and related Fourth Amendment precedent.
The Court held the impoundment was unconstitutional (policy-driven, automatic towing foreclosed alternatives and consent; not justified by Opperman community‑caretaking) and suppressed the fruits of the inventory search.

Issue	Gov't Argument	Trujillo Argument	Held
Whether impoundment was justified under Opperman (community‑caretaking)	Vehicle obstructed entrance/traffic and firearms risk justified tow	Entranceway was not a public, heavily trafficked road; towing unnecessary and could have been avoided	Not justified under Opperman; impoundment unreasonable
Whether impoundment is constitutional under Sanders (standardized policy + reasonable, non‑pretextual community‑caretaking rationale)	Policy satisfied standardized‑criteria prong; location/firearms support caretaking rationale	Automatic policy foreclosed alternatives and consent; no reasonable caretaking basis here	First prong met (policy), second prong failed—impoundment unconstitutional under Sanders
Whether the Sheriff’s impoundment policy is facially invalid	Policy contains an exception for a present registered owner; Sanders does not require blanket prohibition	Policy effectively mandates towing in nearly every arrest, raising facial Fourth Amendment concerns	Court declined to rule facially invalid here but expressed serious concern about the policy’s automatic nature
Remedy: Whether evidence from inventory search must be suppressed	Evidence discovered during inventory after impoundment is admissible if impoundment lawful	Evidence is fruit of an unconstitutional impoundment and must be suppressed	Suppression granted; meth, firearms, and currency excluded

South Dakota v. Opperman, 428 U.S. 364 (1976) (permits warrantless impoundments for legitimate community‑caretaking purposes)
United States v. Sanders, 796 F.3d 1241 (10th Cir. 2015) (impoundment on private property constitutional only if guided by a standardized policy and a reasonable, non‑pretextual community‑caretaking rationale)
United States v. Ibarra, 955 F.2d 1405 (10th Cir. 1992) (invalidated impoundment where officer failed to credibly show public‑safety justification and alternatives existed)
United States v. Pappas, 735 F.2d 1232 (10th Cir. 1984) (Opperman cannot justify automatic towing upon arrest regardless of circumstances)
City of Los Angeles v. Patel, 135 S. Ct. 2443 (2015) (facial Fourth Amendment challenges are not categorically disfavored)