USA V. JONATHAN ANDERSON, No. 20-50345 (9th Cir. 2022)
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Defendant was stopped for a license-plate violation, and deputies from the San Bernardino County Sheriff’s Department (SBCSD) discovered that he had an expired driver’s license and a long criminal history. The deputies conducted an inventory search before towing Defendant’s truck, and, after finding a handgun under the driver’s seat of his truck, arrested Defendant for being a felon in possession of a firearm.
The Ninth Circuit affirmed the district court’s order denying Defendant’s motion to suppress a handgun found during an inventory search of his truck, vacated a condition of supervised release, and remanded. The panel held that the district court did not err in concluding that the government established that a valid community caretaking purpose existed for impounding and inventorying Defendant’s truck before the search was conducted. The panel wrote that the deputies had an objectively reasonable belief that Anderson’s truck, which he had parked in a private driveway, was parked illegally. The panel disagreed with Defendant’s assertion that the deputies’ inventory search was invalid because they failed to comply with the SBCSD’s standardized inventory search procedures.
The panel wrote that the inventory search was conducted pursuant to a standard policy, and was performed in good faith, not solely for the purpose of obtaining evidence of a crime; therefore, the government’s interest in the protection of property and protection of the police outweighed Defendant’s expectation of privacy in the contents of his car, and the search was reasonable for Fourth Amendment purposes.
Court Description: Criminal Law. The panel affirmed the district court’s order denying Jonathan Anderson’s motion to suppress a handgun found during an inventory search of his truck, vacated a condition of supervised release, and remanded, in a case in which Anderson entered a conditional guilty plea to being a felon in possession of a firearm. Anderson was stopped for a license-plate violation, and deputies from the San Bernardino County Sheriff’s Department (SBCSD) discovered that he had an expired driver’s license and a long criminal history. The deputies conducted an inventory search before towing Anderson’s truck, and, after finding a handgun under the driver’s seat of his truck, arrested Anderson for being a felon in possession of a firearm. The panel held that the district court did not err in concluding that the government established that a valid community caretaking purpose existed for impounding and inventorying Anderson’s truck before the search was conducted. The panel wrote that the deputies had an UNITED STATES V. ANDERSON 3 objectively reasonable belief that Anderson’s truck, which he had parked in a private driveway, was parked illegally. The panel noted that the district court found that the homeowner wanted the car off the property and that there was no one available to move Anderson’s truck because Anderson did not have a valid license, he had no passengers with him, and he told the deputies he was not from the area where he was stopped. The panel wrote that the district court did not clearly err in finding that the deputies spoke to the homeowner before conducting the search. Because this finding is entitled to deference, the panel wrote that no remand is required. The panel disagreed with Anderson’s assertion that the deputies’ inventory search was invalid because they failed to comply with the SBCSD’s standardized inventory search procedures. The panel wrote that the inventory search was conducted pursuant to a standard policy, and was performed in good faith, not solely for the purpose of obtaining evidence of a crime; therefore, the government’s interest in protection of property and protection of the police outweighed Anderson’s expectation of privacy in the contents of his car, and the search was reasonable for Fourth Amendment purposes. Applying United States v. Magdirila, 962 F.3d 1152 (9th Cir. 2020), the panel vacated a risk-notification condition of Anderson’s supervised release, and remanded for the district court to craft a condition that accords with Anderson’s criminal history. Dissenting in part, Judge Lee agreed that the inventory search was lawful, but would remand to the district court the issue of whether the officers spoke with the homeowner to verify that Anderson’s car was unlawfully parked outside his 4 UNITED STATES V. ANDERSON house before searching Anderson’s car, given conflicting testimony and the district court’s inaccurate characterization of the record. Dissenting in part, Judge Forrest agreed that a valid community-caretaking purpose existed to impound the truck and conduct an inventory search, but disagreed that the deputies conducted a valid inventory search. She wrote that the Fourth Amendment is violated where, as here, officers are required to prepare a full inventory of the property found during a search of an impounded vehicle and they inventory only that property found that has evidentiary value such that the administrative purposes animating the inventory-search exception are subverted, and there otherwise is no indication that administrative purposes motivated the “inventory” search.
The court issued a subsequent related opinion or order on July 19, 2023.
The court issued a subsequent related opinion or order on May 2, 2024.
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