Also known as: booking search · bookings search · inventory search
Written by attorneys — see sources below.
An administrative inventory of an arrestee's personal belongings conducted at the stationhouse prior to incarceration following a valid arrest. The search serves caretaking purposes such as protecting property, preventing false claims, and ensuring security. Officers may open containers when doing so follows standardized departmental procedures rather than serving as a pretext for investigation.
Officers arrested Brittany Bell for driving while intoxicated and impounded her sedan under department rules. At the impound lot they opened the trunk and a closed duffel bag inside it, listing the contents on an official form. The cash and documents found later supported unrelated charges against Bell.
Police seized Bruce Baldwin's truck from a public street after probable cause showed it was used to transport contraband. They towed it to a secure facility and performed an inventory that uncovered additional narcotics in a locked toolbox. The items recovered during the inventory were admitted at Baldwin's trial.
After arresting Bethany Boyd for disorderly conduct, officers took her to the station and inventoried her backpack per written policy. They opened a sealed envelope inside and recorded cash and a USB drive on the inventory sheet. The contents later became evidence in a separate theft prosecution.
Barbara Bennett's pickup was towed after officers arrested her for driving while intoxicated. At the impound lot, officers followed routine policy and searched the unlocked glove compartment, discovering marijuana. The discovery led to additional charges against Bennett.
On December 10, 1973, a Vermillion, South Dakota police officer observed respondent Opperman's unoccupied vehicle illegally parked in a restricted downtown area between 2 a.m. and 6 a.m. The officer issued an overtime parking ticket and placed it on the windshield, warning that vehicles in violation could be towed. Later that morning, another officer issued a second ticket for the continuing violation, and the circumstances were reported to police headquarters. After inspection, the vehicle was towed to the city impound lot. From outside the car, an officer observed a watch on the dashboard and other personal property on the back seat and floorboard. The car door was unlocked, and using a standard inventory form pursuant to standard police procedures, the officer inventoried the contents, including the unlocked glove compartment, where marijuana was found in a plastic bag. All items were removed to the police department for safekeeping. Respondent Opperman was arrested on charges of possession of marijuana. His motion to suppress the evidence from the inventory search was denied. He was convicted after a jury trial and sentenced to a fine of $100 and 14 days in jail. The Supreme Court of South Dakota reversed the conviction, holding that the evidence had been obtained in violation of the Fourth Amendment. The United States Supreme Court granted certiorari to review the judgment.
View caseOfficers arrested Bianca Baker for public intoxication and brought her to the station. Following written booking policy they opened her purse and catalogued a makeup case and folded papers. The papers later supplied evidence in an unrelated forgery investigation.
Police arrested Bobby Brady on a bench warrant and seized his wallet at booking. Officers opened the wallet per department inventory rules and listed credit cards and receipts. The receipts were later introduced in a separate fraud prosecution.
The search is valid when conducted after a lawful arrest, at the stationhouse before incarceration, and pursuant to standardized departmental procedures that serve administrative purposes such as protecting property and preventing false claims. Officers may open containers if the policy requires it and the search is not a pretext for investigation.
No. When the overarching policy requires a complete inventory of all personal property, officers may open sealed containers to fulfill the administrative duty of cataloging items. The policy's silence does not limit the search if the goal remains a thorough administrative accounting rather than evidence gathering.
The search remains valid if officers follow the standardized policy exactly and the objective administrative character of the procedure predominates. Subjective suspicions do not convert an otherwise proper inventory into an unconstitutional search when the officers adhere to established procedures.
…passenger compartment was valid as a protective search under Terry, supra , and that the search of the trunk was valid as an inventory search under South Dakota v. Opperman , 428 U. S. 364 (1976). See 94 Mich. App. 338, 288 N. W. 2d 629 (1979). The Michigan Supreme Court reversed. The court held that "the sole justification of…