In what circumstances will a police officer be permitted to search a defendant's bag following his arrest?

Finally, in United States v. Bowhay , 992 F.2d 229 (9th Cir. 1993), we considered an inventory search of the defendant's bag following his arrest. The police department's "standard procedure" was that "everything [be] inventoried." Id. at 230. Because "the officer had no discretion," his admission that he searched the defendant's bag based partly on a motive to investigate rather than merely inventory was irrelevant. Id. at 231. We noted that "[w]hen the police conduct would have been the same regardless of the officer's subjective state of mind, no purpose is served by attempting to tease out the officer's true motivation." Id. Thus, we held that the search of the defendant's bag did not violate the Fourth Amendment. Id.