U.S. v. Anderson

“Under the community caretaking exception, police officers may impound vehicles that jeopardize public safety and the efficient movement of vehicular traffic.” Miranda v. City of Cornelius, 429 F.3d 858, 864 (9th Cir. 2005).

Discovering Petitioner drove with an expired license during a stop, police conducted an inventory search when towing a car where they found a handgun. Police arrested Petitioner as a felon in possession of a firearm. Petitioner sought to suppress the evidence, arguing it was an invalid search unconstitutional under the 4th Amendment. The district court denied Petitioner’s motion. Petitioner appealed to the Ninth Circuit, arguing that the district court erred in denying his motion to suppress and that one of his conditions in the supervised release was unconstitutional. The Court held the district court did not err in denying Petitioner’s motion to suppress, as the police, acting as a community caretaker, conducted an inventory search pursuant to a standard procedure rather than discovering evidence of a crime. The Court reasoned that since Petitioner was parked in a stranger’s driveway and unable to drive on an invalid license, the police utilized their ability as a community caretaker to tow the car away and as consequence had to follow a standardized procedure by conducting an inventory search of the car. The Court also held that the condition to Petitioner’s supervised release was unconstitutionally vague and subsequently vacated the condition, remanding for resentencing.