What is the scope of a vehicle inventory search?

California, United States of America


The following excerpt is from People v. Smith, 260 Cal.Rptr.3d 68, 46 Cal.App.5th 375 (Cal. App. 2020):

Vehicle inventory searches are "a well-defined exception to the warrant requirement of the Fourth Amendment." ( Colorado v. Bertine (1987) 479 U.S. 367, 371, 107 S.Ct. 738, 93 L.Ed.2d 739 ( Colorado ).) An inventory search may extend to the cars trunk, glove compartment, and closed containers located within the car. ( Id. at p. 375, 107 S.Ct. 738.) "A police officer may be allowed sufficient latitude to determine whether a particular container should or should not be opened in light of the nature of the search and characteristics of the container itself." ( Florida v. Wells (1990) 495 U.S. 1, 4, 110 S.Ct. 1632, 109 L.Ed.2d 1 ( Florida ).)

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