13 N.Y.3d 9 (2009)
For an inventory search of a vehicle to be valid, the prosecution must demonstrate that the search was conducted according to a standardized procedure designed to produce an inventory, and that the results were fully recorded in a usable format.
Summary
Victor Gomez was arrested for driving with a suspended license, and his vehicle was impounded. Police searched the vehicle, finding drugs and drug paraphernalia. Gomez moved to suppress the evidence, arguing the search was illegal. The New York Court of Appeals held that the prosecution failed to establish a valid inventory search because they did not demonstrate that the search was conducted according to a standardized procedure or that a meaningful inventory was created. The court emphasized that while a formal inventory search form isn’t strictly required, the search must be designed to create an inventory, and the results must be recorded effectively.
Facts
On June 23, 2005, NYPD officers observed Victor Gomez driving erratically. A license plate check revealed Gomez owned the vehicle but his driver’s license was suspended. The officers stopped Gomez, confirmed his license was suspended, arrested him, and impounded his vehicle. An officer, recognizing Gomez from a prior incident involving threats, searched the vehicle. They found drugs, drug paraphernalia, and empty plastic baggies. The search was continued at the precinct due to a gathering crowd.
Procedural History
Gomez was charged with criminal possession of a controlled substance and criminally using drug paraphernalia. He moved to suppress the evidence found in his vehicle. The Supreme Court denied the motion. Gomez pleaded guilty to criminal possession of a controlled substance. The Appellate Division reversed the conviction, granted the suppression motion, and dismissed the indictment. The People appealed to the New York Court of Appeals.
Issue(s)
Whether the People met their initial burden of establishing a valid inventory search of the defendant’s vehicle, justifying the admission of the seized evidence.
Holding
No, because the People failed to demonstrate that the search was conducted according to a standardized procedure designed to produce an inventory, and that the results were fully recorded in a usable format.
Court’s Reasoning
The Court of Appeals relied on its prior holdings in People v. Galak, 80 N.Y.2d 715 (1993), and People v. Johnson, 1 N.Y.3d 252 (2003), reiterating that inventory searches are an exception to the Fourth Amendment’s warrant requirement. The court stated that “[a]n inventory search is . . . designed to properly catalogue the contents of the item searched. The specific objectives of an inventory search, particularly in the context of a vehicle, are to protect the property of the defendant, to protect the police against any claim of lost property, and to protect police personnel and others from any dangerous instruments.” Florida v. Wells, 495 U.S. 1, 4 (1990), was also cited.
The Court found that the People failed to demonstrate the search was conducted according to a standardized procedure, even though the NYPD has a written protocol. They failed to establish the circumstances justifying the search of the closed trunk or door panel. Moreover, the Court stressed the importance of a meaningful inventory. While the arresting officer filled out a voucher and forfeiture paperwork, the People didn’t prove that no other items besides contraband were found. The Court clarified that while using an inventory search form isn’t mandatory, the search must still be designed to produce an inventory with results fully recorded. The Court concluded that the search in this case was not designed to produce an inventory.