Christian Riner was arrested in Brea, California, on a misdemeanor warrant. Following his arrest, police officers impounded his vehicle from a public parking garage and conducted an inventory search, discovering two firearms and over 450 rounds of ammunition. Riner entered a conditional guilty plea to one count of possessing ammunition by a prohibited person in violation of 18 U.S.C. § 922(g)(1) and (g)(9), reserving the right to appeal two constitutional challenges: the constitutionality of the firearm statutes under the Second Amendment and the legality of the vehicle search under the Fourth Amendment. The district court denied his motion to suppress the evidence, finding the inventory search was conducted for legitimate caretaking purposes and not as a ruse for investigation.
The court addressed the Second Amendment challenge first, noting that while the Government argued Riner forfeited the issue by not formally filing a motion to dismiss, the plea agreement preserved the constitutional questions. The court construed any ambiguity in the plea agreement against the Government and found no prejudice. On the merits, the court held that Riner's challenges fail under controlling circuit precedent, specifically citing United States v. Duarte for the constitutionality of § 922(g)(1) as applied to non-violent felons and United States v. Martinez for § 922(g)(9). Regarding the Fourth Amendment claim, the court applied de novo review to the legal conclusion but clear error review to the district court's factual findings. The district court had found that the vehicle posed a significant threat of vandalism or theft and that the officers' primary motivation was caretaking, not investigation. The Ninth Circuit deferred to these findings, noting that a dual motive—one valid and one impermissible—does not render a search pretextual. The court distinguished this case from United States v. Anderson, where the district court failed to make findings on subjective motivations. Furthermore, the court found that the omission of a few items from the inventory form was insufficient to invalidate the search, and it rejected Riner's late assertion that officers denied his wife access to the vehicle, as the claim was unsworn and contradicted by the audio record.
Riner's conviction stands, and the evidence from the inventory search remains admissible. The decision reinforces the Ninth Circuit's stance that prohibitions on firearm possession by felons and domestic violence offenders are constitutionally sound. It also clarifies that inventory searches are valid even if officers have some investigatory motive, provided the primary purpose is caretaking and the search is not a ruse. The ruling leaves open the question of whether a defendant's unsworn assertions regarding alternative custodians for a vehicle can overcome a district court's factual findings if not properly supported in a motion to suppress.
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