Goliday v. State
708 N.E.2d 4, 1999 Ind. LEXIS 163, 1999 WL 151061 (1999)
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Rule of Law:
An officer's warrantless inventory search of a vehicle is constitutional when the preceding impoundment is not a matter of discretion but is required by statute, such as when a vehicle has a stolen license plate and no registration. Furthermore, a defendant's exclusive possession of a vehicle as its sole occupant is sufficient to infer the intent element for constructive possession of contraband found within.
Facts:
- A police officer stopped James E. Goliday, who was the sole occupant and driver of a vehicle, for a traffic infraction.
- Goliday could not produce a driver's license or the vehicle's registration.
- A routine computer check revealed that the vehicle's license plate was stolen and that Goliday had never held a valid driver's license.
- While the officer was conducting the computer check, Goliday fled the scene on foot, abandoning the vehicle.
- Police pursued and apprehended Goliday, who physically resisted being handcuffed.
- A search of Goliday's person revealed over $900 in cash, and he was in possession of the key to the vehicle's trunk.
- Men's clothing belonging to Goliday was found in the trunk, indicating he had been living out of the vehicle.
Procedural Posture:
- James E. Goliday was convicted by a jury in a state trial court of multiple drug and resisting law enforcement offenses.
- The trial court also adjudicated Goliday as a habitual offender.
- Prior to trial, Goliday's motion to suppress the evidence found in the vehicle search was denied by the trial court.
- Goliday, as the appellant, appealed his convictions to the Supreme Court of Indiana, challenging the sufficiency of the evidence and the trial court's denial of his motion to suppress.
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Issue:
Does the warrantless inventory search of a vehicle violate constitutional protections against unreasonable searches when the vehicle was impounded pursuant to a statute because it bore a stolen license plate, lacked registration, and its sole occupant had fled?
Opinions:
Majority - Dickson, J.
No. A warrantless inventory search of a vehicle is constitutional if the preceding impoundment of the vehicle was proper. The court first addressed the defendant's claim of insufficient evidence for constructive possession. Constructive possession requires proof of both intent and capability to maintain control over contraband. The court found Goliday's exclusive possession of the vehicle as its sole occupant was sufficient to infer his intent to control the drugs within. His capability was demonstrated by his possession of the trunk key and the presence of his personal belongings in the trunk alongside the cocaine. Regarding the search, the court distinguished this case from Fair v. State, where an impoundment was discretionary. Here, an Indiana statute (Ind. Code § 9-18-2-43) required the officer to take a vehicle into custody if it had improper plates or no registration. Because the vehicle had a stolen plate and no registration, and its driver had fled, the officer's decision to impound was mandated by statute and therefore proper. A routine inventory search following a lawful impoundment is a valid exception to the warrant requirement.
Analysis:
This decision clarifies the 'inventory search' exception to the warrant requirement by distinguishing between discretionary and mandatory impoundments. It establishes that when a statute directs police to take custody of a vehicle under specific circumstances (e.g., stolen plates), the resulting impoundment is per se reasonable, thereby validating a subsequent inventory search. This precedent provides law enforcement with a clear legal basis for searching vehicles they are statutorily required to impound. The case also reinforces the legal principle that exclusive control over a vehicle strongly implies constructive possession of its contents.
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