The leading case of South Dakota v. Opperman, 428 U.S. 364 (1976), explains why police
impoundments and inventory searches are treated as distinctive processes, which are warranted in
different but frequently overlapping circumstances. Impoundments may be in furtherance of “public
safety” or “community caretaking functions,” such as removing “disabled or damaged vehicles” and
“automobiles which violate parking ordinances and which thereby jeopardize both the public safety
and the ef icient movement of vehicular traffic.” Opperman, 428 U.S. at 368-69. An impoundment
must either be supported by probable cause or be consistent with the police role as “caretaker” of the
streets and completely unrelated to an ongoing criminal investigation. Opperman, 428 U.S. at 370
When a vehicle is lawfully impounded, an inventory search is a judicially created exception
to the warrant requirement of the fourth amendment. Gipson, 203 Ill. 2d at 304 (citing People v.
Hundley, 156 Ill. 2d 135, 138 (1993)). The Supreme Court has identi ied three objectives that are
served by allowing inventory searches: (1) protection of the owner’s property; (2) protection of the
police against claims oflost or stolen property; and (3) protection of the police from potential danger.
Gipson, 203 Ill. 2d at 304 (citing Opperman, 428 U.S. at 369). To be deemed reasonable, the
inventory search must further these objectives, and it will satisfy the fourth amendment as long as the
police procedures are reasonable and administered in good faith. People v. Clark, 394 Ill. App. 3d
344, 348 (2009). The procedures need not be in writing if the police act according to standardized
department procedures for conducting inventory searches. Gipson, 203 Ill. 2d at 306, 309; Clark,
394 Ill. App. 3d at 348.
Three criteria must be met for a valid warrantless inventory search of a vehicle: (1) the
original impoundment of the vehicle must be lawful; (2) the purpose of the inventory search must be