US v. Bullette: In 2013, the DEA investigated a potential PCP lab in the California desert following a house fire. After the local sheriff notified them of suspicious activity at the site, investigators arrived and "observed evidence that suggested someone had been manufacturing PCP on the property." Among that evidence was a trio of abandoned vehicles near large drums of chemicals. One of them, a Pontiac sedan, had no license plate or visible registration. Inside investigators could see "a backpack, amber liquid in bottles . . . believed to be finished PCP (which later turned out to be Pine-Sol), and various documents." All three cars were searched. There were no warrants. For reasons not evident from the opinion, Bullette was charged in Maryland for conspiracy to distribute PCP and moved to suppress the evidence recovered from the Pontiac. He was convicted at trial after the district court denied the motion.
On appeal, the Fourth Circuit affirmed the denial of the motion to suppress. Rolling past an automobile exception analysis or exigent circumstances, the court held that it was inevitable that the evidence in the Pontiac would have been discovered via an inventory search on the car. "Impoundment," the court noted, "constitutes a reasonable course of action when the owner of a vehicle abandons it, or law enforcement cannot identify the owner." That applied to the Pontiac, which was impounded pursuant to standard DEA procedure, which included an inventory search. That there was no written policy about such searches was irrelevant.