People v. Williams

INTRODUCTION

Appellant Ricky Conley Williams challenges his carrying a loaded firearm conviction on the ground the trial court erred by denying his suppression motion. We conclude that impounding appellant’s car, which was legally parked in front of his residence, was unconstitutional, as it served no community caretaking purpose. The subsequent inventory search of the car therefore also was unconstitutional, and the trial court erred by denying appellant’s suppression motion.

BACKGROUND AND PROCEDURAL HISTORY

Santa Monica Police Department Officer Derek Morton saw appellant driving without a seatbelt. He followed appellant’s car and turned on the overhead lights on his police car. Appellant parked at the curb in front of his residence. Appellant provided Morton with a valid driver’s license, but did not have the registration or proof of insurance for the car, which was a rental. Morton determined from his computer check that there was an outstanding arrest warrant for appellant. He placed appellant under arrest, impounded appellant’s car, and searched it. Morton found a loaded gun inside a bag on the backseat.

A jury convicted appellant of carrying a loaded firearm,…