Facts
- A Florida Highway Patrol trooper stopped Martin Leslie Wells for speeding, smelled alcohol, arrested him for DUI, and took him for a breath test.
- Wells’s car was impounded, and he gave permission to open the trunk.
- During an inventory search, officers found two marijuana cigarette butts in an ashtray and a locked suitcase in the trunk.
- At an officer’s direction, impoundment personnel forced the suitcase open and discovered a substantial amount of marijuana.
- Wells was charged with possession of a controlled substance and moved to suppress the marijuana as the product of an unlawful search.
- The trial court denied suppression; Wells entered a nolo contendere plea while reserving his right to appeal the suppression ruling.
Issues
- Whether the Fourth Amendment permits police to open a closed container found during an inventory search of an impounded vehicle when the department has no standardized policy governing the opening of such containers.
Decision
- The Supreme Court affirmed the judgment suppressing the marijuana.
- The Court held that, absent any Highway Patrol policy on opening closed containers during inventory searches, the suitcase search was insufficiently regulated to satisfy the Fourth Amendment.
- The Court rejected the view that departments must choose an “open all containers” or “open no containers” rule; some officer discretion is permissible if guided by standardized criteria or established routine.
Legal Principles
- Inventory searches are valid under the Fourth Amendment only when conducted pursuant to standardized criteria or established routine that limits officer discretion and reduces the risk of investigatory pretext.
- A department may adopt an inventory policy that permits bounded officer discretion to decide whether to open a particular container, provided the discretion is channeled by standardized criteria.
- When no policy exists governing the opening of closed containers, a container search during an inventory risks becoming a general rummaging for evidence and violates the Fourth Amendment.
Conclusion
Because the Florida Highway Patrol lacked any standardized policy governing the opening of closed containers during inventory searches, the forced opening of Wells’s locked suitcase was an unconstitutional exercise of unguided discretion, and the marijuana found inside was properly suppressed.