Autran v. State
In Autran v. State, 887 S.W.2d 31 (Tex. Crim. App. 1994), the court of criminal appeals held that the state constitution provides greater protection than the federal constitution in the context of inventory searches. Id. at 42.
The court stated that police officers may not rely upon the inventory exception to conduct a warrantless search of closed containers in automobiles. Id.