Gauldin v. State

In Gauldin v. State, 683 S.W.2d 411 (Tex. Crim. App. 1984), the police had the authority to impound the vehicle in question. 683 S.W.2d at 415. The police, upon determining to impound Gauldin's vehicle, conducted a search of its contents. Id. At trial, Officer Estep testified that another officer had completed the inventory, but Officer Estep later testified that he did not know if an inventory had actually been completed. Id. at 415 n.3. The Court of Criminal Appeals held, "In the absence of testimony regarding actual adherence to standard police inventory procedure, the State has not sustained its burden of proof." Id. at 415.