In what circumstances will a police officer impound a car after arresting a driver for driving without a driver's license?

In People v. Green (1996) 46 Cal.App.4th 367, the police officers "arrested [the defendant] for driving without a driver's license in violation of Vehicle Code section 12500. The officers impounded the vehicle as there was no other person with a valid license present to take control of the automobile while defendant was taken to jail." (Id. at p. 373.) The court upheld the inventory search, noting "[t]here is no indication that the inventory search of the car was merely a 'ruse' to try to discover evidence of criminal activity." (Id. at p. 374.)

In People v. Steely (1989) 210 Cal.App.3d 889, the police officer cited the defendant for driving with a revoked license and impounded the car. (Id. at pp. 889-890.) The court upheld the subsequent inventory search. "It was not unreasonable for [the officer] to conclude that the appropriate way to protect the vehicle was impoundment," as "there was no other licensed driver, the car was blocking a driveway and [the defendant] was not the registered owner of the vehicle." (Id. at p. 892.)

And in People v. Burch (1986) 188 Cal.App.3d 172, "[t]he officer testified it was his regular procedure upon citing a driver for violation of Vehicle Code section 14601 [for driving with a suspended license] to have the car towed so as to prevent the driver from simply getting back into his vehicle and driving away." (Id. at p. 180.) The court noted in upholding the inventory search, "there is no credible evidence the taking of

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an inventory was simply a 'ruse' to justify an investigatory search for criminal evidence." (Ibid.)