July 21, 2019

Case Law: Pineda v. People, Evidence Discovered Pursuant to Valid Inventory Search of Vehicle

on May 10, 2010.

Fourth Amendment—Inventory Searches—Searches Incident to Arrest.

The Supreme Court affirmed the court of appeals’ denial of defendant Pineda’s motion to suppress heroin evidence found in his vehicle when he was arrested. The trial court initially denied Pineda’s motion to suppress, determining that the evidence was discovered pursuant to a valid search incident to arrest. The court of appeals affirmed. However, after the court of appeals issued its decision, the U.S. Supreme Court decided Arizona v. Gant, __ U.S. __, 129 S.Ct. 1710 (2009), which reformulated the application of the search-incident-to-arrest exception involving motor vehicles. The Court did not decide whether the search-incident-to-arrest exception continues to apply in this case post-Gant. Instead, the Court affirmed on alternate grounds, holding that the heroin evidence was admissible because it was discovered pursuant to a valid inventory search of the vehicle.

Summary and full case also available here.

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