The defendant’s car was seen leaving the site of a robbery. The car was traced and the defendant was arrested as he was entering the vehicle near his home. After a quick search of the car, an officer took the defendant to the police station and impounded the car as evidence. A department regulation stated that an impounded vehicle had to be searched in order to remove all valuables from it. Pursuant to this regulation and without a warrant, an officer searched the car. While he was securing the window, however, he saw and seized the registration card with the name of the robbery victim on it.
Whether the officer discovered the registration card by means of an illegal search?
No. The discovery of the registration card occurred as a result of reasonable measures taken to protect the car while it was in government custody.
The Fourth Amendment does not require the government to obtain a warrant for standard inventories. Once the door of the car had lawfully been opened, the registration card, with the name of the robbery victim on it, was plainly visible. Objects falling in the plain view of an officer who has a right to be in the position to have that view are subject to seizure.
390 U.S. 234, 88 S. Ct. 992 (1968)