Milton Allen was arrested in Raleigh, North Carolina, after interfering with a police investigation of a stolen vehicle. During the arrest, officers placed Allen on the ground, secured his hands and feet, and searched two cross-body bags he was wearing, discovering loaded firearms, drugs, and other contraband. Allen moved to suppress the evidence, arguing the search was unlawful because he was already secured and could not access the bags, citing the Fourth Circuit's prior decision in United States v. Davis. The district court granted the motion, rejecting the government's argument that the evidence would have been found via standard inventory searches. The government appealed, contending that the evidence would inevitably have been discovered through routine processing procedures at the Wake County Detention Center.
Judge Niemeyer, writing for the panel, focused on the inevitable discovery doctrine rather than the validity of the search incident to arrest. The court explained that while the search incident to arrest might have been questionable under United States v. Davis, the evidence was admissible because it would have been lawfully discovered through inventory searches. The court analyzed two policies: the Raleigh Police Department policy and the Wake County Detention Center policy. Both policies required that every arrestee's personal belongings be searched before entry into the detention center or storage. The court found these policies provided standardized criteria that limited officer discretion, preventing the search from being a 'ruse for a general rummaging.' The district court erred in requiring a written copy of the detention center's policy, as testimony regarding standard practices is sufficient. Furthermore, the district judge's personal philosophical objections to the inventory search exception were irrelevant, as lower courts are bound by Supreme Court doctrine. The court concluded that because the policies mandated searching all property of every arrestee, Allen's bags would inevitably have been searched and the contraband discovered.
The decision reverses the suppression order, allowing the firearms and drugs to be admitted as evidence at Allen's trial. It clarifies that inventory search policies do not need to be proven by written documents if testimony establishes standard practices. The case is remanded to the district court for further proceedings consistent with admitting the evidence. The ruling reinforces that the inevitable discovery doctrine applies when standardized policies would have uncovered the evidence regardless of the initial search's validity.