Benavides v. State

In Benavides v. State, 600 S.W.2d 809, 810 (Tex. Crim. App. 1980), police officers were dispatched to a residence where they found the defendant and his wife suffering from firearm wounds. Id. at 810. After the defendant was transported to a hospital, the police officers questioned the defendant's half-brother about the location of the defendant's car and discovered that it was "locked and legally parked about two blocks away from the premises." Id. They then impounded the car, conducted an inventory search, and found the defendant's suicide note, which was admitted into evidence. Id. The court concluded that the impoundment and subsequent inventory search were unlawful, noting that there was "no evidence that the car was impeding the flow of traffic or that it was a danger to public safety" because it was "legally parked in a residential area and it was locked." Id. at 812.