¶12 The Fourth Amendment of the United States Constitution "does not forbid all searches and seizures," but rather, forbids "only those that are unreasonable." State v. Organ, 225 Ariz. 43, 46, ¶ 11, 234 P.3d 611, 614 (App. 2010). Generally, to be considered reasonable, a search "must be conducted pursuant to a warrant issued by an independent judicial officer."
¶7 Generally, in order to search or seize a person, law enforcement officers must have a valid warrant based on probable cause. State v. Organ, 225 Ariz. 43, ¶ 11, 234 P.3d 611, 614 (App. 2010); see also Cady v. Dombrowski, 413 U.S. 433, 439 (1973). But because the Fourth Amendment prohibits only unreasonable searches, there are certain exceptions to the warrant requirement.
Inventory searches are a well-defined exception to the probable cause and warrant requirements of the Fourth Amendment. State v. Organ, 225 Ariz. 43, 48, ¶ 20, 234 P.3d 611, 616 (App. 2010) (citing Colorado v. Bertine, 479 U.S. 367, 371 (1987) and South Dakota v. Opperman, 428 U.S. 364, 370-72 (1976)).
In conducting our review, we view the evidence presented in the light most favorable to upholding the superior court's ruling and defer to the court's findings of fact. State v. Organ, 225 Ariz. 43, 46, ¶ 10 (App. 2010) (citation omitted). ¶11 The Fourth Amendment does not forbid all searches and seizures, only those that are unreasonable.
¶6 Inventory searches are a well-defined exception to the Fourth Amendment's probable cause and warrant requirements. State v. Organ, 225 Ariz. 43, ¶ 20, 234 P.3d 611, 616 (App. 2010).
In deciding the propriety of the court's ruling, we consider only the facts adduced at the suppression hearing, State v. Teagle, 217 Ariz. 17, 20, ¶ 2, 170 P.3d 266, 269 (App. 2007), and we view that evidence in the light most favorable to affirming the ruling. State v. Organ, 225 Ariz. 43, 46, ¶ 10, 234 P.3d 611, 614 (App. 2010).
State v. Wyman, 197 Ariz. 10, ¶ 7, 3 P.3d 392, 395 (App. 2000), quoting Florida v. Royer, 501 U.S. 491, 497 (1983) (alterations in Wyman). If law enforcement officers wish to search or seize an individual, however, ordinarily they must obtain a warrant based on probable cause. State v. Organ, 225 Ariz. 43, ¶ 11, 234 P.3d611, 614 (App. 2010).
"However, 'because the ultimate touchstone of the Fourth Amendment is reasonableness,' those requirements are subject to certain exceptions." State v. Organ, 225 Ariz. 43, 46, ¶ 11 (App. 2010) (quoting Brigham City v. Stuart, 547 U.S. 398, 403 (2006)). One such exception is the "community caretaker" doctrine, which "allows admission of evidence discovered without a warrant when law enforcement engages in 'community caretaking functions' intended to promote public safety."
¶15 A warrantless inventory search is valid under the Fourth Amendment if "(1) law enforcement officials . . . have lawful possession or custody of the vehicle, and (2) the inventory search [was] conducted in good faith and not used as a subterfuge for a warrantless search." State v. Organ, 225 Ariz. 43, ¶ 21, 234 P.3d 611, 616 (App. 2010). If the search is conducted "solely" to discover evidence of a crime, it is invalid.
The community caretaker doctrine allows the admission of evidence discovered without a warrant when law enforcement engages in community caretaker functions that are "totally divorced from the detection, investigation, or acquisition of evidence," but aimed at promoting public safety. Cady v. Dombrowski, 413 U.S. 433, 441 (1973); State v. Organ, 225 Ariz. 43, 46, ¶ 12, 234 P.3d 611, 614 (App. 2010). As we noted in Mendoza-Ruiz, courts are divided on whether actions taken as part of a community caretaker function constitute a search at all because there was no investigatory purpose or are an exception to the warrant/probable cause requirement.