In State v. Phifer, 297 N.C. 216, 254 S.E.2d 586 (1979), a police officer stopped the defendant's vehicle for speeding and discovered that the defendant did not have a driver's license. Phifer, 297 N.C. at 218, 254 S.E.2d at 586-87. Another officer arrived and informed the first officer that he recognized the defendant as a known drug dealer. Id. at 218, 254 S.E.2d at 587. The officers determined that there was an outstanding warrant for the defendant's arrest and they then placed the defendant under arrest. Id. The officers began an inventory search and because there had been break-ins at the location of the stop, the officers decided to call a wrecker to tow the defendant's vehicle. Id. As part of the inventory search, the officers searched the vehicle's glove compartment and discovered marijuana and cocaine. Id. The Supreme Court of North Carolina Court recognized as follows: "'In the interests of public safety and as part of what the Court has called "community caretaking functions," automobiles are frequently taken into police custody. Vehicle accidents present one such occasion. To permit the uninterrupted flow of traffic and in some circumstances to preserve evidence, disabled or damaged vehicles will often be removed from the highways or streets at the behest of police engaged solely in caretaking and traffic-control activities.'" Id. at 219, 254 S.E.2d at 587. The Supreme Court of North Carolina held that the officers failed in two respects to comply with the applicable standard procedures for towing and inventory of vehicles. Id. at 221-22, 254 S.E.2d at 588-89. First, the standard procedures required officers to have authorization from a supervisor before having a vehicle towed or alternatively required that an assisting officer drive the vehicle. Id. However, the officers did not seek authorization nor did they consider whether one of them should drive the vehicle to the magistrate's office. Id. at 222, 254 S.E.2d at 589. Second, despite the fact that the defendant was capable of determining what should be done with the vehicle, the officers did not consult him regarding the disposition of the vehicle. Id. This also violated the applicable procedures governing the towing and inventory of vehicles. Id. The Supreme Court also recognized that while the officers cited the danger of theft and vandalism as their reasons for having the vehicle towed, "it is highly unlikely that a traffic problem would have been created had the defendant desired to risk exposure to theft by leaving his car temporarily parked on the right-of-way, the vacant lot, or a nearby parking space." Id. The Supreme Court of North Carolina further emphasized that because the officers knew that the defendant was a drug dealer and had an outstanding arrest warrant, the officers "utilized the inventory procedure as a 'pretext concealing an investigatory motive.'" Id. at 223, 254 S.E.2d at 589.