United States v. Ramos, No. 23-6071 (10th Cir. 2023)
Annotate this Case
The United States Court of Appeals for the Tenth Circuit ruled that impounding a vehicle from a private property without a reasonable, non-pretextual community-caretaking rationale violates the Fourth Amendment. The defendant, Isaac Ramos, was arrested after an altercation at a convenience store. His truck was impounded from the store's parking lot, and a subsequent inventory search revealed a machine gun and ammunition. Ramos was charged with unlawful possession of a machine gun and being a felon illegally in possession of ammunition. He moved to suppress the evidence, arguing that the impoundment of his truck violated the Fourth Amendment. The district court denied his motion, and he appealed.
The Tenth Circuit reversed the district court's decision, finding that the impoundment was not supported by a reasonable, non-pretextual community-caretaking rationale. The court considered five factors: whether the vehicle was on public or private property; if on private property, whether the property owner had been consulted; whether an alternative to impoundment existed; whether the vehicle was implicated in a crime; and whether the vehicle’s owner and/or driver had consented to the impoundment. The court found that all of these factors weighed against the reasonableness of the impoundment, and thus, it violated the Fourth Amendment. The court remanded the case to the district court with instructions to grant Ramos’s suppression motion and conduct any further necessary proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.