Arsenio Clayton was arrested after firing a gun into the air during a family dispute. Deputies found a loaded handgun in a plastic grocery bag on the roof of his stalled vehicle. Clayton moved to suppress the gun, arguing the search violated the Fourth Amendment. The district court denied the motion, finding that the gun would have been discovered during a routine inventory search of the towed vehicle. Clayton pleaded guilty but reserved his right to appeal the suppression ruling.
The Sixth Circuit applied the inevitable discovery doctrine, an exception to the exclusionary rule. The court reasoned that even if the initial search of the bag was unlawful, the evidence would have been found lawfully. The Sheriff's Office policy required towing the vehicle because it was obstructing traffic and the suspect had requested a tow. Once a vehicle is towed, policy mandates an inventory search of all accessible areas, including closed containers. The court found that the deputies had already decided to tow the car and photograph its contents before finding the gun. Clayton's arguments that his consent to the tow was coerced or that the deputies failed to follow paperwork procedures were rejected. The court noted that imperfect documentation does not invalidate a search if the decision to tow and inventory was independent of the discovery of the contraband.
The conviction stands as the evidence was properly admitted. The ruling reinforces that inventory searches are valid even if officers fail to complete every line on an inventory form, provided the decision to tow and search was made for legitimate reasons. It clarifies that the inevitable discovery doctrine applies when routine police procedures would have uncovered the evidence regardless of the initial search.
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