How has the court interpreted the doctrine of impounding a vehicle under the Fourth Amendment?

The Shafrir court cited several cases in support of its analysis, including United States v. Smith (3d Cir. 2008) 522 F.3d 305 (Smith). In that case, the court held that a city police officer's decision to impound a vehicle was reasonable under the Fourth Amendment, despite the fact that the city's police department had no "standard policy regarding the impoundment and towing of vehicles" at the time. (Smith, supra, at pp. 310, 314-315.) The court concluded that the officer's decision to impoundin order to avoid leaving the vehicle in an area where it was subject to being damaged, vandalized, or stolenwas reasonable under the circumstances. (Id. at pp. 314-315.)

In this case too, the police officer's conduct following appellant's arrest⁴ was reasonable under all the circumstances. We reject appellant's argument that the record compels the conclusion that the decision to tow the vehicle and search it were part of a ruse perpetrated for the purpose of conducting a criminal investigation. As to the impound decision, we conclude, under the principles of appellate review summarized above, that the trial court reasonably could credit the police testimony that the decision to tow was made because appellant's truck was parked in someone else's driveway and because the officer was concerned the truck would be vandalized if left where it was. (Smith, supra, 522 F.2d at pp. 314-315 [impound reasonable where officer testified vehicle towed out of concern it would be damaged, vandalized or stolen]; United States v. Jensen (9th Cir. 2005) 425 F.3d 698, 706 ["Once the arrest was made, the doctrine allowed law enforcement officers to seize and remove any vehicle which may impede traffic, threaten public safety, or be subject to vandalism"]; Hallstrom v. City of Garden City (9th Cir. 1993) 991 F.2d 1473, 1477, fn. 4 [impoundment of arrestee's car from private parking lot "to protect the car from vandalism or theft" was reasonable under the community caretaking function].) Further, we conclude the decision to conduct an

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