California, United States of America
The following excerpt is from People v. Williams, 20 Cal.4th 119, 83 Cal.Rptr.2d 275, 973 P.2d 52 (Cal. 1999):
For example, in Colorado v. Bertine (1987) 479 U.S. 367, 107 S.Ct. 738, 93 L.Ed.2d 739 (Bertine ), the high court recognized that police have a legitimate interest in taking an inventory of the contents of a vehicle, including closed containers inside that vehicle, before towing it. This inventory serves "to protect an owner's property while it is in the custody of the police, to insure against claims of lost, stolen, or vandalized property, and to guard the police from danger." (Id. at p. 372, 107 S.Ct. 738.) The court stated that "inventory searches are now a well-defined exception to the warrant requirement of the Fourth Amendment." (Id. at p. 371, 107 S.Ct. 738.) Nevertheless, the court also recognized the risk that police might use an inventory of this kind as a pretext for searching a vehicle for contraband or other evidence. (Id. at pp. 375-376, 107 S.Ct. 738.) Accordingly, the court emphasized that police must "follow[ ] standardized procedures." (Id. at p. 372, 107 S.Ct. 738; see also id. at p. 374, fn. 6, 107 S.Ct. 738.) "[R]easonable police regulations relating to inventory procedures administered in good faith satisfy the Fourth Amendment." (Id. at p. 374, 107 S.Ct. 738.)
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