In this case the defendant Lyle was observed parking and exiting a vehicle in midtown Manhattan. NYPD arrested him when they observed an illegal “gravity knife” clipped to his pants. Lyle was driving a rental car he was not authorized to drive. He also had a suspended license. Lyle was arrested for driving on a suspended license and carrying the knife. Officers impounded the vehicle and an inventory revealed over a pound of methamphetamine. Lyle argued that he had a reasonable expectation of privacy (REP) in the rental car and the search was unlawful and he further argued the impound was unlawful.
The Second Circuit (in downtown Manhattan) noted the recent Supreme Court decision in Byrd v. United States where the court held there is no de facto rule that an unauthorized driver has no REP in a rental car. But the Second Circuit distinguished this case from Byrd in that Lyle was unlawfully driving the vehicle on a suspended license. The court went on to hold that the Community Caretaking exception permitted the impound of the vehicle (South Dakota v. Opperman, 428 U.S. 364 (1976)).
TIP: This case provides a good narrative about impounding a vehicle and the “circuit splits” over what is required. The opinion is 51 pages long and discusses a host of issues that are not relevant to this update, but the discussion on what is required in each circuit is worth a review.
To read or download the full opinion CLICK HERE