Coleman, C.J.
Defendant was convicted of receiving stolen property valued at more than $100. In a 1 to 1 to 1 decision, the Court of Appeals reversed, finding that defendant was arrested without probable cause and that he and his automobile had been improperly searched. 70 Mich App 7; 245 NW2d 384 (1976).
We reverse and reinstate the conviction.
I
While investigating a stolen car ring on March 14, 1972, officers of the Michigan State Police Intelligence Section, Organized Crime Unit, had staked out the Telegraph House Motel parking lot. They were watching a 1972 Continental Mark IV which had been identified as stolen and which was known to have an altered vehicle identification number (VIN).
Two other automobiles, a 1969 Cadillac (Ohio license plates) driven by defendant and a Ford Maverick, entered the motel parking lot sepa[236]*236rately. The persons in the cars went into the motel separately, but the drivers of the stolen Mark IV, the Cadillac, and the Maverick left the motel together. They then drove the vehicles on the same route, followed by the state police officers and officers of the Southfield police.
All three cars under surveillance pulled into the same gas station on Nine Mile Road and stopped.
At the gas station, Southfield Officer McKee asked defendant for his license and the Cadillac’s registration. The defendant gave Officer McKee a license and a purported registration for the car.1 McKee handed the documents to his partner, Southfield Officer George. Officer George had been specially trained in the identification of altered VINs. He compared the VIN on the registration proffered by the defendant with the VIN stamped on a plate affixed to the dashboard of the Cadillac in plain view. The VINs matched each other but the VIN on the dashboard appeared to have been altered. At trial, Officer George testified:
”Q. Okay. Now, Officer, when you looked at that VIN plate out there at the scene, at the gas station, did you observe anything about it?
"A. Yes, sir, I observed that two numbers appeared to be out of line with the rest.
”Q. And, which two numbérs, please?
"A. The first two numbers are 2 and 4 were the numbers.
[237]*237"Q. Okay. And, you did observe that with the naked eye?
"A. Yes, sir, I did.
"Q. Now, Officer, if you recall, did you confiscate the VIN plate or someone else?
"A. Someone else did, sir.
"Q. Now, Officer, what transpired next after the VIN plate was checked?
"A. At that time I informed Mr. Brooks that we would further — we would like to further check as far as ownership of the vehicle, and asked him if he would mind coming into the station while this check took place.
”Q. And, did Mr. Brooks reply?
"A. He said he didn’t mind, he would come in.”
The license given by the defendant to the officers was in the defendant’s name, but the purported registration bore the name of a Mr. Willie J. Benman of Ohio.2
In the Court of Appeals, Judge T. M. Burns wrote an opinion with Judge D. E. Holbrook, Jr., concurring only in the result. Judge V. J. Brennan dissented. Judge Burns said there could "be little dispute that defendant was under arrest when he accompanied the police officer to the Southfield police station”.
We do not know the state of defendant’s mind as to whether he thought he could refuse the "invitation”, but we will give defendant the benefit of his argument that he was in fact arrested at the gas station.
Judge Burns concluded there was an arrest and [238]*238that it was made without reasonable or probable cause.3
Judge Brennan’s dissent reviewed the circumstances and found them "highly suspicious”:
"Defendant was brought under surveillance and was stopped by police because he was driving a vehicle clearly travelling in tandem with two other automobiles, one of which was known to be stolen. The stolen automobile, a Continental Mark IV, was known to have a false VIN plate. All of the vehicles had been originally observed together at the Telegraph House Motel before leaving the motel in a group. In addition, they all travelled in identical route for several blocks to the gas station. Certainly the police officers acted reasonably in stopping and investigating defendant when the vehicles pulled up at the gas station.”
He said Officer George’s discovery that the Cadillac’s VIN plate was altered provided reasonable cause to arrest, a facet of the whole not addressed by Judge Burns.
MCL 764.15(a); MSA 28.874(a) allows a policeman "without a warrant, [to] arrest a person * * * for the commission of any * * * misdemeanor committed in his presence(Emphasis added.)
It is a misdemeanor to ’’misrepresent the identity of a motor vehicle * * * by removing or defacing the manufacturer’s serial number [the [239]*239VIN] * * * or by replacing any part of such motor vehicle * * * bearing the serial number * * * with a new part, upon which the proper serial number * * * has not been stamped”. (Emphasis added.) MCL 750.415; MSA 28.647.4 Possession of a motor vehicle with an "altered” VIN is, under this statute, "prima facie evidence of violation” of this law.
Under the circumstances of this case, the officers were justified in concluding that the defendant was "misrepresent[ing] the identity of a motor vehicle” in their presence. They had observed the defendant driving a late model Cadillac (a frequent target of stolen car rings) and leaving a motel and traveling together with a late model Lincoln Continental Mark IV (also a frequent target of stolen car rings). They knew also that the VIN on the Continental had been altered and that the car had been stolen. When they asked the defendant for the Cadillac’s registration, he handed them a registration bearing the name of Mr. Willie J. Ben-man of Ohio. They observed that the VIN on the Cadillac’s dashboard also had been altered and that the VIN on the purported registration proffered by the defendant matched the altered VIN on the dashboard. These observations, taken together, were more than sufficient to justify a con[240]*240elusion that the defendant was "misrepresenting] the identity of a motor vehicle” in their presence.
It is true that the officers did not observe the defendant physically altering the VIN on the Cadillac’s dashboard, although they did observe the misrepresentation — and herein lies the critical point of difference between the analyses in our opinions.
We cannot attribute to the Legislature the intention that the police must witness both the physical act of altering and the act of misrepresenting in order to arrest a defendant without a warrant for commission of this crime.
At the outset, we consider the meaning of "misrepresentation” and observe that it cannot be accomplished by viewing one’s own work as it is being done (i.e., in this case, altering the VIN). Black’s Law Dictionary (4th ed) provides this definition of misrepresentation:
"Any manifestation by words or other conduct by one person to another that, under the circumstances, amounts to an assertion not in accordance with the facts.” (Emphasis added.)
To interpret the statute as requiring that the police must witness both the altering and the misrepresentation would for all practical purposes make the statute unenforceable. Persons engaged in the illicit business of stealing and disposing of cars for cash do not ply their trade in public. VIN numbers are not likely to be altered in broad daylight and in plain view. They are doctored in the secrecy of garages and "chop shops” throughout the state. Therefore, the physical act of alteration is rarely observed. Furthermore, stolen automobiles are extremely mobile and fungible. Within [241]*241hours they can be driven to another state or country or they can be dissected into their component parts, irrevocably beyond identification or recovery.
We believe the Legislature was aware of these facts when it made possession of a motor vehicle with an "altered” VIN "prima facie” evidence of commission of this crime.5 When, as here, a police officer observes the accomplished fact of physical alteration together with an act of misrepresentation, it would make little sense to send the possessor freely on his or her way. By the time a warrant could be obtained, the culprit and the car would be long gone.
For these reasons, we hold that the arrest of the defendant at the gas station was valid. Therefore, the Cadillac, which was the primary evidence of the crime, was properly seized incident to the arrest.
II
After defendant’s Cadillac was driven to the Southfield Police Station, it was inspected by Robert Campbell of the National Automobile Theft Bureau. He agreed it "was obvious from looking at [the VIN plate that] it was not an original factory plate or the one inserted by the factory”. Among the factors noted was that "the numbers are not straight as when they are automatically embossed”.
After checking the plate, Mr. Campbell crawled under the car to check the identification numbers stamped on the outside of the engine and frame. They did not match the numbers on the VIN [242]*242plate. A computer check of the true numbers showed that the Cadillac was stolen. (See fh 2.)
Judge Burns said that Mr. Campbell had searched the car. He found no justification for the search and concluded that "evidence of the correct vehicle identification numbers, that the VIN plate had been tampered with and the resulting evidence that the car had been stolen should have been suppressed”.
He assumed there had been a search. Judge Brennan said "the search for the proper VIN was not an illegal 'search’ and the results were admissible at trial”.
The first inquiry is "whether or not there was a search”, "whether * * * the police conduct violated the defendant’s reasonable expectation of privacy”.6 The test to determine if a search occurred can be simply stated: "if an individual has a reasonable expectation of privacy in the area searched * * * a search has been conducted”.7
In People v Valoppi, 61 Mich App 470; 233 NW2d 41 (1975) (cited by Judge Brennan), the police checked a hidden VIN to determine that a car was stolen. The defendant said there was an illegal search. The Court of Appeals found "no search took place” citing United States v Johnson, 431 F2d 441 (CA 5, 1970), and United States v Polk, 433 F2d 644 (CA 5, 1970).
The Johnson decision was an en banc affirmance of an earlier opinion. The circuit judges found
"that inspections of motor vehicles performed by police officers, who were entitled to be on the property where the vehicles were located, which in no way [243]*243damaged the vehicles and were limited to determining the correct identification numbers thereof were not searches within the meaning of the Fourth Amendment; and that alternatively, if either of such inspections constituted a Fourth Amendment search, then no search warrant was necessary because such inspections were reasonable and did not violate the right of the people to be secure in their persons, houses, papers or effects”.
Johnson was further explained in Polk which held there can "be no reasonable expectation of privacy with respect to the identity of the VIN”. Polk was extensively quoted in Valoppi.
The Seventh Circuit considered a situation similar to ours in United States v Zemke, 457 F2d 110 (CA 7, 1972), cert den, 406 US 947 (1972). An Indiana state policeman noticed two motorcyclists parked under a bridge and stopped to see if they needed assistance. They did not. The officer then checked their licenses and "glanced” at the vehicle identification numbers. The numbers "appeared to him to have been changed”. In Indiana, as in Michigan, it is prima facie evidence of a crime to possess a vehicle with altered numbers.
The officer told the cyclists about the law and said he "would like to look into it a little more carefully”. The cyclists agreed to go with him to a service station down the road. While there, the officer discovered that the hidden serial numbers did not match the visible ones. He arrested both cyclists.
On appeal, the cyclists said the officer "did not have probable cause to search their vehicles without their consent and * * * did not have probable cause to arrest them” until after the search. The Seventh Circuit found the contentions "meritless”.
The Court found "nothing unreasonable nor any [244]*244improper invasion of the defendants’ rights” in the officer’s noting that the identification numbers appeared altered:
"Even if the officer’s glance had brought merely the-suggestion of an alteration to his mind it should not in our opinion be a basis for him just to drop the matter there subject to checking through records back at the post while the cyclists proceeded merrily toward unknown destinations.”
The Court did not "consider the police activity at the roadside spot as being a search”. Even if it were considered a search, "it would bring into play the application of the 'plain view’ doctrine”.
The Court said the officer had "adequate probable cause” to check hidden numbers at the original site. Therefore
"[sjince the completion of the inspection was permissible at the point of first contact it did not become less so when and where actually conducted”.
Similarly, in the case at bar, because it would have been proper at the gas station to compare the true VIN under the car with the altered VIN plate in plain view above (and because the seizure and transportation of the car to the station was proper), it was not less proper at the police station. There is no reasonable expectation of privacy in the VIN itself. All such numbers are on the. outside of the automobile, or they are in plain view. No entry is required to read the VIN. The means taken by the police to read this VIN did not invade a constitutionally protected area.
Ill
After Mr. Campbell found the VIN on the un[245]*245derside of the Cadillac and after a computer check disclosed that the Cadillac was stolen, defendant was formally arrested. He was taken to the booking room where an inventory search was made.
When defendant took off his left sock, Officer McKee noticed a small piece of paper tucked into it. In contrast to removal of his shoes and right sock, defendant removed the left sock carefully and slowly and appeared to be trying to tuck the paper further into it with his thumb. The officer shook the sock and a "peach or flesh-colored” folded piece of paper fell out. It appeared to Officers McKee and George to be a temporary driver’s license. When Officer McKee unfolded it, he found it was in fact a temporary driver’s license for Willie J. Benman, the same name as that on the registration which defendant displayed at the gas station. The license was admitted into evidence at trial after a suppression hearing.
Judge Burns said that "[s]ince the incarceration of the defendant was unjustified, the inventory search which produced the temporary driver’s license was invalid”. Judge Brennan described the search as occurring "[o]nly following formal, valid arrest”.
Defendant concedes in this Court that if the original arrest was lawful, "the seizure of the folded paper in the instant case would not be the result of a search and must be regarded as proper”. However, defendant claims that "the unfolding and inspection of the seized paper presents an entirely new and separate situation” and that a search warrant was necessary prior to its unfolding and subsequent admission into evidence.
In People v Henry Robinson, 37 Mich App 115; 194 NW2d 537 (1971), the defendant had been improperly arrested. During an inventory search, [246]*246the police saw a lighter which connected defendant with another crime. The majority refused to suppress the lighter because defendant had not objected to its admission prior to trial or when it was introduced.
The concurrence noted:
"When a person is arrested and jailed it is a customary procedure to require him to remove and deposit his personal belongings with the jailer.
"Information obtained by a police officer through the exercise of his senses as he observes articles being removed by a prisoner from his pockets and transferred to a receptacle for safekeeping is not information obtained as a result of a search.”
In People v Robinson, 388 Mich 630; 202 NW2d 288 (1972), our Court affirmed, agreeing with the reasoning of the majority and with those two paragraphs of the concurring opinion.
The defendant in People v Obadele, 58 Mich App 139; 227 NW2d 258 (1975), was arrested for carrying weapons in a car. At the station house, he was searched. The police found three vials in a pouch attached to his belt. One vial contained a controlled substance. While not a search incident to an arrest, the Court said the station house search "was a proper 'inventory search’ and the controlled substance should not have been suppressed”.
In People v Walker, 58 Mich App 519; 228 NW2d 443 (1975), the defendant was arrested on an outstanding nonsupport warrant. During the station house inventory search, the police noticed a piece of tinfoil in his hair. They took it, opened it up and found heroin.
On appeal, defendant argued that opening the packet was an illegal search. The Court said an [247]*247inventory procedure "is designed to prevent the introduction of weapons and contraband * * * and is a protective measure for police and prisoner alike”. The Court said it "would be naive and pointless to assume that law enforcement officials may store an arrestee’s personal effects without first determining what it is they are inventorying”.
The defendant in People v Rivard, 59 Mich App 530; 230 NW2d 6 (1975), was arrested for armed robbery. During the inventory, the police noticed he was wearing a blue sapphire ring. The next day a detective reviewed a list of stolen property and realized that the ring could be connected with the robbery. He obtained it from defendant’s personal property.
Defendant moved to suppress the ring saying it was the result of an illegal search. The Court of Appeals rejected this argument:
"The item had remained in police custody after having been discovered when defendant deposited his personal belongings with police prior to being jailed. Defendant concedes that no warrant would have been required to seize the ring during the inventory. * * * Thus, a search warrant to again look at the ring, already in police custody, does not make sense. * * * [A]ny expectation of privacy with respect to that item had at least partially dissipated so that no reasonable expectation of privacy was breached by Detective Van Alstine taking a 'second look’ ”.8
Even more to the point is United States v Edwards, 415 US 800; 94 S Ct 1234; 39 L Ed 2d 771 (1974), where articles of clothing were taken from the defendant ten hours after his arrest. The Court said "it is difficult to perceive what is unrea[248]*248sonable about the police examining and holding as evidence those personal effects of the accused that they already have in their lawful custody as the result of a lawful arrest”. The Court found that the First Circuit "captured the essence of situations like this” in United States v. DeLeo, 422 F2d 487 (CA 1, 1970):
"While the legal arrest of a person should not destroy the privacy of his premises, it does — for at least reasonable time and to a reasonable extent — take his own privacy out of the realm of protection from police interest in weapons, means of escape, and evidence.”
Under the agreed facts of our case, it was reasonable for the officer to unfold what appeared to be a temporary driver’s license. The fulcrum of the investigation was a car theft ring to which each police discovery was firmly attached. The furtive behavior of defendant, the color and appearance of the piece of paper he was trying to hide, the stolen car and the disparity between driver’s license (Brooks) and registration (Benman) would have led reasonable persons even less highly trained than the officers to believe the folded paper was evidence of the crime. Under these circumstances, the contention of defendant that the unfolding constituted a "search” within an inventory search must be met. with the conclusion that it was not a search because there is no reasonable expectation of privacy in a temporary driver’s license, and even if wé were to hold it to have been a "search” it was reasonable.9
However, the paper was properly admitted into [249]*249evidence under at least two other theories offered by the people.
(1) It was reasonable to unfold the paper to determine what was being inventoried. (E.g., if it had been lost or misplaced, defendant could have claimed it was a negotiable instrument or something else of value.)
(2) It was reasonable to look in the folded paper for small but dangerous objects, for drugs, or for other contraband.
Under any theory here proposed, the judge did not err in ruling, after a suppression hearing, that the temporary driver’s license was admissible in evidence.
IV. Summary
The initial sequence of events culminated when defendant, another driver and a man in an automobile known to be stolen and under surveillance drove the same route to the same gas station and stopped. At this point, two Southfield police officers approached defendant and lawfully asked him to produce his driver’s license and automobile registration. MCL 257.311; MSA 9.2011 and MCL 257.223; MSA 9.1923. They were in different names. A check of the registration with the VIN in plain view on the dashboard revealed the same number — but a VIN visibly altered. The numbers were out of line. It is a misdemeanor to conceal or misrepresent the identity of a motor vehicle by using certain devices and it is prima facie evidence of such an offense to be in possession of a car with an altered identification number. The arrest of the defendant, whether it occurred at the gas station or at the police station, was valid. The Cadillac was properly seized incident to the arrest.
[250]*250Although there is some question whether an arrest actually was made, at that time, we give defendant the benefit of his argument that he was in fact arrested. The officers or another expert could have crawled under the car and checked the VIN on the frame and engine. The car was driven instead to the police station.
The next sequence of events took place in the police station when an expert did in fact crawl under the automobile to see the VIN stamped on the underside. No entry of the car was necessary. There was no "search” needed to compare the dashboard VIN with those on the outside of the car but on the underside.
There was no reasonable expectation of privacy in the identification numbers and no unlawful intrusion to obtain them. Even if we had agreed with defendant that a search took place, it would have been permissible at the gas station and given the fact that the car was properly seized and transported "did not become less so at the police station”. (Zemke.) There was no invasion of a constitutionally protected area. The police at no time exceeded their authority.
When it was verified at the police station that the automobile was stolen, defendant was placed under formal arrest for car theft and the third sequence took place. The only question remaining was whether unfolding the temporary driver’s license in defendant’s left sock during the inventory search was technically a "search” within the valid inventory search so that a search warrant was required to unfold the paper. Under any of the proposed theories, defendant must fail. Again, no constitutionally protected area was invaded. There is no reasonable expectation of privacy in a temporary driver’s license, believed to be such when [251]*251unfolded by an officer. It was obtained with no unlawful intrusion upon defendant’s person or protected property. The officer’s actions under these circumstances were reasonable. Further, the unfolding would have been lawful under either of the prosecutor’s other proffered theories.
When considering the boundaries of "unreasonable searches and seizures”, we constantly are faced with the conflict between the need to apply realistic standards of law enforcement and the need to protect citizens from unreasonable intrusions into their privacy.10
Sometimes forgotten in debate is the word "unreasonable”. It means excessive, beyond a normal or proper limit. It means exceeding limits set by good judgment or fairness. In law, there can be no absolute definition of "unreasonable”. Each determination must be made within a specific context.
This being so, there is nothing in the circumstances of this case which compels a conclusion that an unreasonable search occurred. What was done was reasonable and within the limits set by good judgment and fairness.
The Court of Appeals is reversed and the conviction reinstated.
Williams, Fitzgerald, and Ryan, JJ., concurred with Coleman, C.J.