Washington v. Peck (Majority and Dissent)
Annotate this CaseIn January 2016, Michael Peck and Clark Tellvik were seen on a security camera, burglarizing a home. The owner of the home was demonstrating her home's new surveillance system to a friend on her phone when she saw the crime in progress. She called 911, and officers arrived at the home within minutes. When officers arrived, a Dodge Dakota pickup truck was stuck in the snow in front of the house. Peck and Tellvik were outside the truck, trying to free it from the snow. The officers contacted Peck and Tellvik, frisked them, and detained them. Additional responding officers arrived within minutes, ran the registration of the vehicle, and discovered it was stolen. Officers arrested Peck and Tellvik for possession of a stolen vehicle. During the inventory search of the vehicle that was ultimately impounded, an officer discovered a "black zippered nylon case" that seemed to hold CDs (compact disks), and opened it. Inside the black zippered nylon case was packaged methamphetamine, an electronic scale, and a smoking pipe. The State charged Peck and Tellvik with several crimes, including possession of a controlled substance with intent to deliver. Peck and Tellvik moved to suppress the contents of the black zippered nylon case. The trial court denied the motion to suppress, finding the inventory search to be proper and finding no evidence of pretext. Peck and Tellvik were subsequently convicted. Both appealed their controlled substance convictions. The Court of Appeals reversed the trial court's denial of the motion to suppress. The issues this case presented for the Washington Supreme Court’s review centered on: (1) whether defendants had standing to challenge the scope of a warrantless inventory search of a vehicle when that vehicle was stolen; and (2) whether a proper inventory search extends to opening an innocuous, unlocked container of unknown ownership found in a stolen vehicle associated with defendants who were apprehended while burglarizing a home. The Supreme Court held that defendants had automatic standing to challenge the search and that the search of the innocuous container was lawful under these circumstances. The Court reversed the Court of Appeals and upheld the denial of the motion to suppress.
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