United States v. Venezia, 995 F.3d 1170

On January 2, 2019, Lakewood police stopped an Audi after observing a turn without signaling and license plates displayed inside the passenger compartment.
The driver, Hunter Venezia, had no license, registration, insurance, or title and was arrested on an outstanding misdemeanor warrant; the vehicle was legally parked in a private motel lot in a high-crime area.
Officers could not reach the vehicle’s registered owner that night and did not ask the motel or a named companion if someone could take custody of the car.
Officers impounded the car pursuant to Lakewood Police Department (LPD) written impoundment policy and conducted an inventory search that uncovered methamphetamine and other incriminating items.
Venezia moved to suppress the evidence; the district court denied suppression, he pleaded conditionally, and the Tenth Circuit reversed, holding the impoundment violated the Fourth Amendment and directing vacatur of conviction and sentence.

Issue	Venezia's Argument	Government's Argument	Held
Whether the impoundment of a vehicle parked on private property was constitutional under the community-caretaking doctrine (Sanders two-prong test).	Impoundment violated the Fourth Amendment because officers lacked a reasonable community-caretaking rationale and did not exhaust alternatives; LPD policy cannot excuse an unreasonable impoundment.	Impoundment was authorized by LPD standardized policy and justified to protect the vehicle from theft/vandalism in a high-crime motel lot.	Reversed: standardized-policy prong satisfied, but impoundment failed the community-caretaking-prong—officers lacked a reasonable, non-pretextual justification to impound rather than leave the vehicle.
Whether LPD written policy alone is sufficient to justify an impoundment on private property.	Policy cannot override Fourth Amendment reasonableness; Venezia argued the municipal code did not authorize private-lot impoundments in these circumstances.	LPD policy provided standardized criteria that cabin officer discretion and thus satisfies Sanders prong one.	Court: standardized criteria requirement met—Sanders prong one satisfied; compliance with local code not decisive for Sanders analysis.

Cady v. Dombrowski, 413 U.S. 433 (1973) (recognizes community-caretaking exception permitting impoundment of disabled/abandoned vehicles)
South Dakota v. Opperman, 428 U.S. 364 (1976) (illustrates community-caretaking impoundments to protect public safety and traffic flow)
Colorado v. Bertine, 479 U.S. 367 (1987) (upholds inventory searches following impoundment if guided by standardized criteria and not investigatory pretext)
United States v. Sanders, 796 F.3d 1241 (10th Cir. 2015) (articulates two-prong test for private-property impoundments: standardized criteria + reasonable, non-pretextual community-caretaking rationale)
United States v. Kornegay, 885 F.2d 713 (10th Cir. 1989) (upholds impoundment when owner identity unknown and no caretaker available)
United States v. Pappas, 735 F.2d 1232 (10th Cir. 1984) (invalidates impoundment under an overbroad/automatic arrest-to-impound policy)
United States v. Johnson, 734 F.2d 503 (10th Cir. 1984) (upholds impoundment to protect vehicle from vandalism when arrestee cannot provide custody)
Riley v. California, 573 U.S. 373 (2014) (reiterates the Fourth Amendment preference for warrants and exceptions when proper)