The following excerpt is from U.S. v. Mathnay, 895 F.2d 1418 (9th Cir. 1990):
3 This exception is normally used to justify searches where a police department has an established, administrative inventory procedure that is followed when an arrested person is jailed. Illinois v. Lafayette, 462 U.S. 640 (1983). Neither the district court's opinion nor the record reflects evidence that such a procedure was followed.
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