Chauncy Rhodes v. State of Indiana

50 N.E.3d 378, 2016 Ind. App. LEXIS 9, 2016 WL 225571
CourtIndiana Court of Appeals
DecidedJanuary 19, 2016
Docket49A02-1503-CR-173
StatusPublished
Cited by4 cases

This text of 50 N.E.3d 378 (Chauncy Rhodes v. State of Indiana) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chauncy Rhodes v. State of Indiana, 50 N.E.3d 378, 2016 Ind. App. LEXIS 9, 2016 WL 225571 (Ind. Ct. App. 2016).

Opinions

May, Judge.

Chauncy Rhodes appeals his conviction of Class D felony possession of marijuana with a prior conviction of possession of marijuana.1 As the trial court abused its discretion when it admitted evidence obtained from an inventory search of Rhodes’ vehicle, we reverse.

Facts and Procedural History2

On August 18, 2014, Officer Dustin Greathouse saw Rhodes driving over the speed limit. Officer Greathouse initiated a traffic stop, and Rhodes parked his vehicle in a nearby driveway. Rhodes initially told Officer Greathouse he pulled into the driveway because his cousin lived there; Rhodes later admitted he was trying to avoid Officer Greathouse because Rhodes was driving with a suspended license.

Officer Greathouse arrested Rhodes for driving with a suspended license and decided to tow the car. Before he towed the car, Officer Greathouse conducted an --inventory search of the glove box, trunk, and passenger- compartment. He found “numerous personal items,” (Tr. at 13), and “miscellaneous items,” (id: at 49), for which he did not create a record. Officer Greathouse also found a half-eaten pizza, a pizza delivery bag, and a jar of money. In the glove box, Officer Great-house found a “réd metal grinder,” (id. at 49), containing “a small amount of marijuana.” (Id.) At some point before the car was towed, someone from the house came outside to ask if everything was okay and to “make sure the ear was not going to be left in the driveway.” (Id. at 11.) .

Before his bench trial, Rhodes filed a motion to suppress the items found as part of the inventory search on the ground the search violated his rights under the Fourth Amendment of the United States Constitution and Article 1, Section 11 of the Indiana Constitution. -After a hearing, Rhodes’ motion was denied. He objected to the admission of the same evidence during trial, and his objection was overruled. The trial court found Rhodes guilty [381]*381of Class A misdemeanor possession of marijuana and Class A misdemeanor driving while suspended.3 It enhanced the marijuana possession conviction to a D felony based on Rhodes’ prior conviction of marijuana possession after Rhodes stipulated to the prior conviction.

Discussion and Decision

[5] Rhodes did not seek interlocutory review of the denial of his motion to suppress but instead appeals following trial. This issue is therefore “appropriately framed as whether the trial court abused its discretion by admitting the evidence at trial.” Lundquist v. State, 834 N.E.2d 1061, 1067 (Ind.Ct.App.2005). Our review of rulings on the admissibility of evidence is essentially the same whether the challenge is made by a pre-trial motion to suppress or by trial objection. Id. We do not reweigh the evidence, and we consider conflicting evidence most favorable to the trial court’s ruling. Id. However, we must also consider the uncontested evidence favorable to the defendant. Id.

[6] The Fourth Amendment to the United States Constitution requires law enforcement officials to obtain a valid warrant before conducting searches or seizures. State v. Straub, 749 N.E.2d 593, 597 (Ind.Ct.App.2001). However, “on occasion the public interest demands greater flexibility than is offered by the constitutional mandate” of a warrant. Rabadi v. State, 541 N.E.2d 271, 274 (Ind.1989). The exceptions to the warrant requirement are “few in number and carefully delineated.” United States v. United States Dist. Court for Eastern Dist. Of Mich., Southern Division, 407 U.S. 297, 313, 92 S.Ct. 2125, 32 L.Ed.2d 752 (1972).

[6-11] [7] One exception to the warrant requirement is an inventory search of a properly impounded vehicle. Fair v. State, 627 N.E.2d 427, 430 (Ind.1993). The purposes of an inventory search are: “1) protection of private property in police custody; 2) protection of police against claims of lost or stolen property; and 3) protection of police from possible danger.” Gibson v. State, 733 N.E.2d 945, 956 (Ind.Ct.App.2000). The test of constitutionality for an inventory search is reasonableness. Id. Our Indiana Supreme Court laid out in Fair the test for reasonableness with regard to an inventory search:

In determining the reasonableness of an inventory search, courts must examine all the facts and circumstances of a case— This examination typically encompasses two overlapping sets of circumstances. First, the propriety of the impoundment must be established because the need for the inventory arises from the impoundment. Second, the scope of the inventory must be evaluated. Where either is clearly unreasonable, the search will not be upheld. In borderline cases, however, the ultimate character of the search is often most clearly revealed when both the necessi-tousness of the impoundment and the scrupulousness of the inventorying are viewed together.

627 N.E.2d at 431.

[8] The inventory search was unreasonable because the State did not prove the scope of the search complied with official police policy.4 “The circum[382]*382stances of the intrusion must also indicate that the search was carried out under routine department procedures which are consistent with the protection of officers from potential danger and false claims of lost or stolen property and the protection of those arrested.” Friend v. State, 858 N.E.2d 646, 652 (Ind.Ct.App.2006).5

In Edwards v. State, 762 N.E.2d 128, 133 (Ind.Ct.App.2002), aff'd on reh’g, 768 N.E.2d 506 (Ind.Ct.App.2002), the State’s evidence did not

include the substance of any police department policy regarding inventory searches, or even indicate there is such a policy. To show that its actions come within the inventory exception, the State must do more than offer the bald allegation of law enforcement that the search was conducted as a routine inventory. The trial court therefore had no eviden-tiary basis to evaluate whether the inventory search performed on Edwards’ truck was in conformity with established local law enforcement policy.

Edwards relied op Stephens v. State, 735 N.E.2d 278 (Ind.Ct.App.2000), as an example of sufficient evidence of police procedure. In Stephens, the State presented evidence in the form of

the records • detailing] who towed the car, indicating] the detective responsible for the investigation, and describing] the valid traffic hazard basis for the tow.

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Bluebook (online)
50 N.E.3d 378, 2016 Ind. App. LEXIS 9, 2016 WL 225571, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chauncy-rhodes-v-state-of-indiana-indctapp-2016.