Search & seizure; Inventory search; The inevitable discovery doctrine

The court concluded that “under the facts of this case . . . the trial court erred by granting defendant’s motion to suppress evidence discovered during the search of his vehicle because the evidence was not obtained in violation of [his] search and seizure rights under the United States and Michigan Constitutions.” Thus, it reversed the order of the trial court granting his “motion to suppress evidence found during the search of” his vehicle and remanded. This interlocutory appeal stemmed from a search of his SUV following a traffic stop. The court agreed “with the prosecution’s claim that the evidence found in defendant’s spare tire compartment would have inevitably been discovered during an inventory search.” Thus, it held that the “prosecution established that the search of [the] vehicle was justified under the inventory-search exception to the warrant requirement.” Therefore, it concluded “the evidence obtained by way of the search is admissible at trial.”