United States v. Alfonso Mancera-Londono, AKA Alfonso Mancera, United States of America v. Jose Rigo Sanchez-Gonzales

We are asked to decide whether the “inevitable discovery” exception to the exclusionary rule may be invoked where the law enforcement agency, pursuant to its oral policy, requires inventory searches of rental cars before return to their owners.

I

On September 22, 1988, DEA agents began surveillance of the Pacifica Hotel in Los Angeles after receiving an FBI tip that a cocaine transaction involving suspected drug dealers was likely to occur there that day. At approximately 7:00 a.m., the agents observed two men, later identified as defendants Jose Sanchez and Alfonso Mancera, leave Room 108. The agents followed Sanchez and Mancera to the hotel parking lot, where they entered and then drove away in a station wagon. The agents ran a check on the station wagon’s license plate number and learned that the vehicle was registered to Budget Rent-a-Car. The defendants engaged in counter-surveillance tactics by driving around certain city blocks numerous times and making U-turns before stopping for Sanchez to get into a pickup truck. After engaging in more counter-surveillance activity, the defendants both drove back to the parking lot of the Pacifica Hotel in their respective…