In this case, the defendant challenged the lawfulness of an inventory of an impounded RV which ultimately led to the discovery of contraband for which the defendant was prosecuted.  Inventories are a judicially recognized exception (JRE) to the warrant requirement. The search of a vehicle to inventory its contents must be reasonable under the totality of the circumstances and may not be ‘a ruse for a general rummaging in order to discover incriminating evidence.’” Florida v. Wells, 495 U.S. 1 (1990)

In affirming the District Court’s judgment denying the defendant’s motion to suppress, the Eighth Circuit held that the inventory search in this case was done properly and in accordance with policy and was not a ruse for criminal evidence.

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