State v. Noel

I concur with the majority opinion. I write separately to address any contention that the illegal narcotics sought to be suppressed would have inevitably been discovered during the police’s inventory search of the subject vehicle even had Officer Adams scrupulously complied with Arizona v. Gant, 556 *344U.S. 332, 129 S.Ct. 1710, 173 L.Ed.2d 485 (2009), by not conducting a search of the passenger compartment incident to Mr. Noel’s arrest. The. majority opinion properly concludes that the State failed to carry its burden to prove that the police conducted a valid inventory search' of the vehicle…