to protect the owner’s property, to protect the police from claims of lost, stolen, or vandalized
property, and to guard the police from danger; and (3) the inventory search must be conducted in
good faith pursuant to reasonable standardized police procedures and not as a pretext for an
investigatory search. Hundley, 156 Ill. 2d at 138.
A. The Impoundment
The threshold issue in considering whether the police have conducted a valid inventory search
incident to a tow is whether the impoundment of the vehicle was proper. See People v. Mason, 403
Ill. App. 3d 1048, 1054 (2010); Clark, 394 Ill. App. 3d at 348. Pursuant to their community-
caretaking function, police have authority to seize and remove from the streets vehicles impeding
traffic or threatening public safety and convenience. Opperman, 428 U.S. at 369; Mason, 403 Ill.
App. 3d at 1054; Clark, 394 Ill. App. 3d at 348. However, the fact that the defendant’s car would
be left unattended without the tow is not a sufficient reason for impoundment unless the vehicle
would be parked illegally. Mason, 403 Ill. App. 3d at 1054; Clark, 394 Ill. App. 3d at 348.
Hucker testified that he followed Zion police department guidelines that require an officer to
impound a vehicle and perform an inventory search when (1) the driver lacks a valid license, (2) there
is no proof of insurance, and (3) no other driver is available to take the vehicle. For the following
reasons, we determine that the Zion police department guidelines are consistent with the Illinois
Vehicle Code (625 ILCS 5/1—100 et seq. (West 2008)) and relevant case law regarding
Severalprinciples ofstatutory interpretation are relevant to the threshold issue of whether the
impoundment of the vehicle was proper pursuant to the Vehicle Code. The primary rule of statutory
construction is to ascertain and give effect to the intent of the legislature. People v. Donoho, 204 Ill.