United States v. Trujillo, No. 19-2212 (10th Cir. 2021)
Annotate this CaseThe government appealed a district-court order granting Defendant Gabriel Trujillo’s motion to suppress evidence recovered during an inventory search of his vehicle following his arrest for failing to pull over in response to a police command. When officers ultimately made contact with Defendant, they learned Defendant was wearing a bulletproof vest and had handguns in the car for protection because "friends of his ex-girlfriend had made threats against his life." Disbelieving Defendant’s explanation for why he had failed to pull over earlier, the arresting officer decided to arrest him. Consistent with the policy of the Bernalillo County Sheriff’s Office (BCSO), the officer also determined that the car should have been impounded and towed. The officer testified he thought it would be dangerous to leave the vehicle where it was, both because its location presented a danger to other drivers, and because of the risk that someone would remove the firearms - particularly because there was a high incidence of auto burglaries and thefts in the area. When the vehicle was searched, along with the firearms, a small backpack locked with a luggage lock was in the passenger compartment, containing a white crystalline substance believed to be methamphetamine. Defendant was indicted on charges of: (1) possession with intent to distribute at least 50 grams of a substance containing methamphetamine; and (2) possession of a firearm in furtherance of a drug-trafficking crime. Defendant argued that the BCSO's impoundment policy was itself unreasonable because there was no community-caretaker basis for impoundment, and the officer failed to consider alternatives to towing. After review of the district court record, the Tenth Circuit held that the search was justified as an exercise of law-enforcement community-caretaker functions, as described in South Dakota v. Opperman, 428 U.S. 364 (1976), and Cady v. Dombrowski, 413 U.S. 433 (1973). The district court was reversed and the matter remanded for further proceedings.
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