California Vehicle Code 22651 (P) - Example Case

In People v. Green (1996) 46 Cal.App.4th 367, police officers stopped a car for an expired registration and discovered that the driver, who was alone in the car, did not have a valid driver's license. (46 Cal.App.4th at p. 370.) The officers decided to impound the car in accordance with section 22651, subdivision (p). On the passenger seat they found a rock of cocaine. A subsequent search turned up a glass crack pipe in the defendant's front pants pocket. (Id. at pp. 370-371.) The Court of Appeal upheld the search as a valid inventory search despite the fact that the prosecution produced no written department policy authorizing impoundment and search in those circumstances. (Id. at pp. 371-376.) The court held the Vehicle Code itself provided the "standardized police procedure" required.