UNITED STATES OF AMERICA v. RAYMOND BULLETTE, III, a/k/a Scrap
US Court of Appeals for the Fourth Circuit, Duncan, April 20, 2017,
Inventory Search – Government does not need to provide a written inventory policy to prove an inventory search, so long as testimony

This opinion is completely ludicrous. Cars can be towed any time the government can’t ID the owner. A car is abandoned as soon as you step away from it. An inventory search doesn’t require conformance with a departmental policy. The police can tow vehicles from private property with no explanation. The DEA can declare private property a “crime scene” and manifest its own right to be there.
I have no problem with the car search under: Carroll, exigency, community caretaking (non-inventory). What this was not, however, was inevitable discovery due to an inventory search.

Inventory Search requires:
1) Circumstances reasonably justifying seizure or impoundment
2) The search must be conducted according to “routine and standard procedures”

Supreme Court: The authority of police to seize and remove from the streets vehicles impeding traffic or threatening public safety and convenience is beyond challenge.

Inevitable discovery: The exclusionary rule does not apply where the government can show by a preponderance of the evidence that police would have inevitably discovered the evidence in question

This opinion also includes lines that are HIGHLY improbable precedent:
“Impoundment constitutes a reasonable course of action when… or law enforcement cannot identify the owner”
“Here, law enforcement encountered the Pontiac–with no visible license plate or registration–in what appeared to be a state of recent abandonment, and they could not identify the owner of the Pontiac.” (didn’t check VIN, vehicle wasn’t “abandoned”)