Facts
- A Boulder, Colorado police officer arrested Steven Lee Bertine for driving under the influence while operating his van.
- After Bertine was taken into custody and before the van was towed to an impound lot, an officer inventoried the van’s contents pursuant to local police procedures.
- During the inventory, the officer opened a closed backpack and found controlled substances, cocaine-related items, and a large amount of cash.
- Bertine moved to suppress the evidence.
- The trial court ruled the search did not violate the Fourth Amendment but suppressed under the Colorado Constitution.
- The Colorado Supreme Court affirmed suppression on Fourth Amendment grounds.
- The U.S. Supreme Court granted certiorari.
Issues
- Whether the Fourth Amendment permits the admission of evidence found during a warrantless inventory search of an impounded vehicle conducted under standardized police procedures, including the opening of closed containers.
Decision
- The Supreme Court reversed and held the evidence was admissible.
- The Court held that the Fourth Amendment does not bar use of evidence found during a vehicle inventory search conducted in good faith pursuant to standardized procedures, even when closed containers are opened.
- The Court rejected a requirement that police perform a case-by-case balancing before opening containers during an inventory.
- The Court held that some officer discretion (such as whether to impound or secure the vehicle) does not invalidate an inventory search when exercised under standard criteria and not based on suspicion of criminal activity.
Legal Principles
- Inventory searches of lawfully impounded vehicles are a recognized exception to the warrant requirement when undertaken for caretaking purposes and conducted under standardized procedures.
- The warrant and probable-cause requirements are not directed at inventories whose purposes include protecting property in police custody, reducing claims of loss or theft, and protecting officers from danger.
- Opening closed containers during an inventory may be reasonable if done in good faith under standardized procedures, rather than as a pretext to investigate criminal conduct.
- Police discretion is permissible if guided by standard criteria and exercised on grounds other than suspicion of evidence of crime.
Conclusion
A warrantless inventory search of an arrestee’s vehicle, including the opening of closed containers, is reasonable under the Fourth Amendment when conducted in good faith pursuant to standardized police procedures for caretaking purposes, allowing the resulting evidence to be used in a criminal prosecution.