In what circumstances will the court allow the police to search and inventory the contents of a vehicle seized by the police?

Our decision in Mozzetti v. Superior Court (1971) 4 Cal.3d 699, 94 Cal.Rptr. 412, 484 P.2d 84, condemned the common police practice of routinely searching and inventorying the contents of all impounded vehicles; while the police may observe and inventory items in plain sight, they may not, in the absence of probable cause, open and search closed areas of the vehicle or closed containers within the car. (See 4 Cal.3d at p. 707, 94 Cal.Rptr. 412, 484 P.2d 84.) We find that Mozzetti controls the present case; we conclude that the superior court erred in denying defendant's motion to suppress the evidence in question. ¹

Page 731