United States v. Snoddy, No. 19-6089 (6th Cir. 2020)
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Trooper Malone stopped Snoddy for speeding and learned that there were Georgia warrants out for Snoddy’s arrest, including for drug crimes. Malone and another officer arrested Snoddy on the warrants. Malone suspected that Snoddy might have drugs in the car. Immediately after making the arrest, the officers sought consent to search the car. Snoddy refused. Malone stated, “I’m gonna have to get the car towed ... and we have to do an inventory on the car.” Malone repeatedly asked Snoddy for consent, warning Snoddy that if he did not consent, the car would be inventoried. Roughly eight minutes after the arrest, Malone called the tow truck but continued to seek consent. About five minutes after calling the truck, Malone began conducting an inventory. Malone discovered and seized approximately one pound of methamphetamine, two handguns, and a set of scales.
Snoddy unsuccessfully moved to suppress the drugs and guns. The Sixth Circuit affirmed the denial of the motion. Snoddy conceded that the traffic stop was lawful, that his arrest was valid, that it was within Malone’s discretion to impound the car, and that an inventory was required once Malone decided to tow the car. Snoddy did not challenge the scope of the search. The district court did not err in rejecting his argument that the decision to impound and inventory the car was a pretext for a warrantless investigative search.
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