Manalansan v. State

We undertake the consideration of this appeal with the mental set still intact that we first articulated in Dixon v. State, 23 Md. App. 19, 20-21, 327 A.2d 516, to the effect that "no aspect of Fourth Amendment litigation has afflicted law enforcement with the yawning credibility gap wrought by inventory searches.”

We begin with the bedrock proposition that the inventorying of the contents of an automobile is not a constitutionally-permitted investigative technique. A search for evidence within an automobile may only be undertaken pursuant to a validly issued search and seizure warrant,…