Inventory Searches  (See Full Document for Citations)


After lawfully taking custody of property, police may conduct a warrantless search of that property if the owner's diminished expectation of privacy is outweighed by the government's interest in satisfying one of three purposes: (1) protecting the owner's property while it is in police custody; (2) protecting the police against claims of lost or stolen property; or (3) protecting the police from potential danger. Because the justification for the search is the production of an inventory of the container's contents, police may not conduct an inventory search in bad faith or solely for investigative purposes. Nevertheless, an inventory search may be justified by legitimate inventory purposes despite the presence of additional investigative motives.

Inventory searches are only valid if conducted according to standardized criteria and procedures. Within the framework of these criteria, however, officers may exercise discretion to determine the appropriateness and scope of an inventory search, and they are not required to use the least intrusive means to secure property lawfully in their possession.

Courts have upheld inventory searches of vehicles lawfully in police custody, including searches of the passenger compartment, glove compartment, trunk (with some exceptions), engine compartment, and any containers in the vehicle. Police may search containers and items in the possession of lawfully detained individuals. In addition, government officials may inspect seemingly abandoned property to determine the owner's identity, to protect public safety, or to inventory the property for safekeeping.