US v. Mathews: Mathews was pulled over after an officer noticed his obscured license plate. Before the car was stopped, the officer recognized Mathews and confirmed his believe that Mathews had an outstanding warrant for his arrest. The car was stopped and Mathews arrested. Also in the car was an unlicensed 17 year old and an infant, neither of which could drive the car away. Therefore, the officer impounded the car. As a result of the impound, he performed an inventory search that resulted in the discovery of drugs in some luggage in the trunk. Mathews unsuccessfully tried to suppress the evidence found in the trunk and then entered a conditional guilty plea.
On appeal, the Fourth Circuit affirmed the district court's denial of Mathews's motion to suppress. The court rejected Mathews's argument that the search was not a proper inventory search because the policy under which the officer searched the car did not detail how to deal with closed containers. No specific provision in the inventory search protocol was needed to search closed containers. The court also rejected Mathews's argument that the search was improper because the inventory search protocol did not sufficiently curtail the discretion of the searching officer.