People v. Steeley

31 Citing cases

  1. People v. Benites

    9 Cal.App.4th 309 (Cal. Ct. App. 1992)   Cited 47 times
    In Benites, impoundment was reasonable because the vehicle was on a "dark, lonely and isolated stretch of road," and the defendant, who had a suspended license, might have driven off after the officer left.

    ( Id. at p. 376, fn. 7 [93 L.Ed.2d at p. 748].) This court again addressed these issues in People v. Steeley (1989) 210 Cal.App.3d 887 [ 258 Cal.Rptr. 699]. Defendant was pulled over for having a burned-out headlight.

  2. People v. Stafford

    H036350 (Cal. Ct. App. Feb. 24, 2012)

    By the same token, unreasonable procedures do not ipso facto become standard, and therefore legal, merely because they are contained in a written directive." (People v. Steeley (1989) 210 Cal.App.3d 887, 891.) " 'The fact that there may be less intrusive means of protecting a vehicle and its contents does not render the decision to impound unreasonable. [Citation.]' [Citation.]" (People v. Benites (1992) 9 Cal.App.4th 309, 325 (Benites).)"[A]n impoundment decision made pursuant to standardized criteria is more likely to satisfy the Fourth Amendment than one not made pursuant to standardized criteria. [Citation.] However, the ultimate determination is properly whether a decision to impound or remove a vehicle, pursuant to the community caretaking function, was reasonable under all the circumstances.

  3. People v. Shafrir

    183 Cal.App.4th 1238 (Cal. Ct. App. 2010)   Cited 43 times
    Recognizing that the protection of a "vehicle from damage or theft" is an "eminently reasonable community caretaking justification"

    The inventory search in Needham was reasonable in scope. In People v. Steeley (1989) 210 Cal.App.3d 887 [ 258 Cal.Rptr. 699], the police impounded an automobile that had defective headlights, the defendant driver was without identification, and the check with the Department of Motor Vehicles disclosed his license was suspended. After deciding to impound the vehicle, and while conducting an inventory search, the police found a handgun in a sleeping bag in the rear of the car.

  4. People v. Flores

    No. B206483 (Cal. Ct. App. Jan. 29, 2010)

    An inventory search is constitutionally unreasonable when used as a ruse to conduct an investigatory search. (Colorado v. Bertine, supra, at pp. 371-372; People v. Steeley (1989) 210 Cal.App.3d 887, 891-892.) In Opperman, the defendant’s vehicle was impounded because it was illegally parked.

  5. People v. Cruz

    No. B207962 (Cal. Ct. App. May. 19, 2009)

    [Citation.] Such searches are unreasonable and therefore violative of the Fourth Amendment when used as a ruse to conduct an investigatory search. [Citation.]” (People v. Steeley (1989) 210 Cal.App.3d 887, 891-892.) Former Vehicle Code section 22651, states, in relevant part: “Any peace officer,... may remove a vehicle located within the territorial limits in which the officer... may act, under any of the following circumstances: [¶]... [¶] (g) When the person or persons in charge of a vehicle upon a highway or any public lands are, by reason of physical injuries or illness, incapacitated to an extent so as to be unable to provide for its custody or removal.

  6. People v. Aguilar

    228 Cal.App.3d 1049 (Cal. Ct. App. 1991)   Cited 23 times
    Invalidating inventory search because the officer "testified one, if not the only, purpose of the impound was to conduct an investigatory search."

    Moreover, even if the Calipatria Police Department had a policy requiring the impound of all vehicles whose drivers had been cited, the policy would not necessarily be reasonable. (See People v. Steeley (1989) 210 Cal.App.3d 887, 891 [ 258 Cal.Rptr. 699]: "unreasonable procedures do not ipso facto become standard, and therefore legal, merely because they are contained in a written directive.") (2) "It is well settled that inventories of impounded vehicles are reasonable where the process is aimed at securing or protecting the car and its contents.

  7. People v. Lemol Mou

    No. B326010 (Cal. Ct. App. Apr. 2, 2024)

    Yet, "[t]he fact that there may be less intrusive means of protecting a vehicle and its contents does not render the decision to impound unreasonable." (People v. Steeley (1989) 210 Cal.App.3d 887, 892 (Steeley), citing Colorado v. Bertine (1987) 479 U.S. 367, 374-375 (Bertine).)

  8. The People v. P.H. (In re P.H.)

    No. B324894 (Cal. Ct. App. Aug. 15, 2023)

    After hearing argument, the juvenile court took the matter under submission and later denied the motion, relying on Colorado v. Bertine (1987) 479 U.S. 367 (Bertine), People v. Steeley (1989) 210 Cal.App.3d 887 (Steeley), and People v. Benites (1992) 9 Cal.App.4th 309. The court concluded the vehicle was towed pursuant to normal police protocols and the caretaking function, and the search of containers in the vehicle was part of towing policy.

  9. People v. Takerian

    C083378 (Cal. Ct. App. Oct. 26, 2017)

    After impounding a vehicle, an inventory search may be conducted without first obtaining a search warrant provided it is conducted pursuant to standardized criteria or established routine, written or unwritten, and it is not merely a pretext or ruse for an investigatory search. (Florida v. Wells (1990) 495 U.S. 1, 4 ; Colorado v. Bertine (1987) 479 U.S. 367, 372 ; South Dakota v. Opperman (1976) 428 U.S. 364, 373 ; People v. Williams (1999) 20 Cal.4th 119, 126; People v. Needham (2000) 79 Cal.App.4th 260, 266; People v. Steeley (1989) 210 Cal.App.3d 887, 889.) An officer has the authority under state law to impound a vehicle when a defendant, who is driving or in control of a vehicle, is taken into custody.

  10. People v. Aceves

    F065993 (Cal. Ct. App. May. 1, 2014)

    (Id. at p. 327.) In People v. Steeley (1989) 210 Cal.App.3d 887 (Steeley), the police officer cited the defendant for driving with a revoked license and impounded the car. (Id. at pp. 889-890.)