341 F. Supp. 3d 1280
D.N.M.2018Background
- At ~2:41 a.m. on Dec. 6, 2017, Deputy Skroch observed a Mustang speeding and attempted a traffic stop; the driver did not immediately stop and later sprinkled a substance from the vehicle window.
- The vehicle ultimately stopped at a gated community; deputies conducted a felony stop, handcuffed and arrested Gabriel Trujillo. Deputies observed multiple firearms in the car and believed Trujillo wore body armor.
- After arrest, Deputy Skroch read Miranda warnings; Trujillo spoke and said the gun(s) and backpack were his and that he’d been searching for a safe place to pull over.
- The car was to be towed under Bernalillo County Sheriff’s Department policy, which requires a complete inventory of property in impounded vehicles and permits opening containers if done without damage and per SOP.
- Deputy Skroch opened a locked green backpack (initially testified he “defeated” the lock but lock and pack were later shown undamaged) and found a handgun, ~½ pound methamphetamine, and bundled currency; he also found a rifle in the vehicle.
- Trujillo moved to suppress statements and the evidence from the backpack, arguing his consent was involuntary and the Department lacked a policy authorizing opening closed/locked containers; the Court denied the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Trujillo's post-arrest statements should be suppressed under Miranda | Trujillo contended statements should be suppressed (argued involuntary) | Government: deputy gave Miranda; statements voluntary and admissible | Court: Miranda warnings given; no deficiency alleged or shown; statements admissible |
| Whether opening and searching the locked backpack violated the Fourth Amendment | Trujillo: Department lacked a written policy explicitly allowing opening closed/locked containers; search was unconstitutional | Government: search was an inventory search pursuant to standardized Bernalillo County policies (tow/inventory rules); deputy acted in good faith and did not damage property | Court: inventory exception applies; deputy followed standardized criteria and acted in good faith; search lawful and evidence admissible |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (warnings required before custodial interrogation)
- Colorado v. Bertine, 479 U.S. 367 (inventory searches pursuant to reasonable police regulations administered in good faith satisfy Fourth Amendment)
- South Dakota v. Opperman, 428 U.S. 364 (inventory searches serve caretaking purposes and are an exception to warrant requirement)
- Florida v. Wells, 495 U.S. 1 (inventory-search policies must provide standardized criteria governing opening closed containers)
- United States v. Sanders, 796 F.3d 1241 (10th Cir.) (impoundment and inventory of vehicles on private property constitutional only if justified by standardized policy and non-pretextual community-caretaking rationale)