When a police officer impounded a stolen SUV and found that the vehicle was full of stolen arrow keys and stolen mail, what is the effect of the search?

MultiRegion, United States of America

The following excerpt is from United States v. Lopez, No. 18-50101 (9th Cir. 2018):

Moreover, the officers did not exceed the permissible scope of a search under the automobile exception. The officers suspected Lopez and his passenger were engaged in crimes against the postal service, and arrow keys and stolen mail could have been concealed anywhere in the SUV. The officers searched only the parts of the SUV that reasonably could have contained the fruits of the suspected crimes. See United States v. Ross, 456 U.S. 798, 825 (1982) (holding that search

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under the automobile exception extends only to areas "that may conceal the object of the search").

7. The district court's finding that the officers would have inevitably discovered the evidence in the SUV was not clearly erroneous. See United States v. Ruckes, 586 F.3d 713, 718 (9th Cir. 2009) ("The inevitable discovery doctrine is an exception to the exclusionary rule" that "permits the government to rely on evidence that ultimately would have been discovered absent a constitutional violation."). The officers learned the SUV had been reported stolen and, under police-department procedures, they properly impounded it. They therefore could have conducted an inventory search, which would have inevitably revealed the evidence of mail theft.

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