What is the scope of a search of a hidden compartment in a vehicle?

hidden compartment has been encompassed by an inventory policy permitting the opening of closed containers. The Attorney General analogizes the search here to the inventory search in United States v. Jackson (6th Cir. 2012) 682 F.3d 448, where police found a gun on the floor of an SUV under ripped up carpet. The circuit court in Jackson found the search, which involved lifting a loose flap of carpet from the floorboard, to be within the policy authorizing a search of " all

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interior ... areas' " of a vehicle. ( Id . at pp. 455457 ) The Attorney General quotes language from United States v. Ross (1982) 456 U.S. 798, 821, 102 S.Ct. 2157, 72 L.Ed.2d 572, cited in Bertine , that "distinctions ... between glove compartments, upholstered seats, trunks, and wrapped packages ... must give way to the interest in the prompt and efficient completion of the task at hand." But that passage described a "precisely defined" vehicle search pursuant to a warrant, which "would support a search of every part of the vehicle that might contain the object of the search." ( Ibid . ) It was not referencing a warrantless inventory search, the scope of which is circumscribed by established police protocol.

In our view, the facts of this case are analogous to those in United States v. Best (8th Cir. 1998) 135 F.3d 1223 ( Best ) and United States v. Lugo (10th Cir. 1992) 978 F.2d 631 ( Lugo ), both involving contraband hidden in a vehicle behind the door panel. In Best , the state trooper noticed two car windows were not functioning properly. Using his flashlight, he saw what appeared to be a bag of marijuana in one of the door cavities and proceeded to pull away the door panel. In concluding that the actions exceeded the permissible scope of an inventory search, which was limited to the contents of the vehicle including the opening of any opaque containers, the court explained that the trooper did not have a legitimate interest in seeking out property hidden behind a door panel because the owner would not have a legitimate claim for protection of such property. ( Best , at p. 1225.)