United States v. Peter Unakalu
Opinion
Opinion
MEMORANDUM
An inventory search is a “well-defined exception to the warrant requirement of the Fourth Amendment.” Colorado v. Bertine, 479 U.S. 367, 371 , 107 S.Ct. 738 , 93 L.Ed.2d 739 (1987). Such a search is reasonable so long as officers exercise their discretion ‘“according to standard criteria and on the basis of something other than suspicion of evidence of criminal activity.’ ” Florida v. Wells, 495 U.S. 1, 4 , 110 S.Ct. 1632 , 109 L.Ed.2d 1 (1990) (quoting Bertine, 479 U.S. at 375 , 107 S.Ct. 738 ). The officers conducted this inventory search after defendant’s rental car was impounded and he asked that his belongings be taken for safe-keeping. The officers followed the Seattle Police Department’s standard inventory policy, which requires officers to search for contraband, narcotics, explosives, hazardous materials, perishable items, money and weapons. This necessarily involves looking within closed containers, thus making the officers’ search of defendant’s sealed envelopes rea sonable under the Fourth Amendment. Because we find that the inventory search was reasonable, it is unnecessary to decide whether defendant’s consent was valid.