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Law School Case Brief

Florida v. Wells - 495 U.S. 1, 110 S. Ct. 1632 (1990)

Rule:

Standardized criteria, or established routine must regulate the opening of containers found during inventory searches. This rule is based on the principle that an inventory search must not be a ruse for a general rummaging in order to discover incriminating evidence. The policy or practice governing inventory searches should be designed to produce an inventory. The individual police officer must not be allowed so much latitude that inventory searches are turned into a purposeful and general means of discovering evidence of crime.

Facts:

Defendant's car was impounded after he was placed under arrest for driving under the influence, and he gave the state trooper permission to open the car's trunk. An inventory search of the car turned up a locked suitcase in the trunk. The police forced the suitcase open and found a garbage bag containing a large amount of marijuana inside. Defendant was charged with possession of a controlled substance, and he filed a motion to suppress the marijuana, claiming that the seizure was in violation of the Fourth Amendment. The trial court denied his motion, the state appellate court reversed the trial court's judgment, and the Supreme Court of Florida affirmed.

Issue:

Does the Fourth Amendment allow the police to open closed containers during an inventory search where the suspect gave permission to open the trunk where the container was found?

Answer:

No.

Conclusion:

The Court affirmed the state appellate court and the state supreme court. The Court held that standardized criteria must regulate the inventory procedures such as opening closed containers found during inventory searches. The police should not be given so much latitude that inventory searches become a purposeful and general means of discovering evidence of crime. The highway patrol had no policy concerning the opening of closed containers found in an inventory search. Absent such a policy, the search of defendant's car was not sufficiently regulated to satisfy the Fourth Amendment.

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