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Name: United States v. Ruckes
Case #: 08-30088
Court: US Court of Appeals
District 9 Cir
Opinion Date: 11/09/2009
Summary

Although a car search was not properly incident to arrest, the evidence obtained was admissible because it would have inevitably been discovered. Ruckes was stopped by a Washington State trooper for a speeding violation, and was unable to produce any identification or driver’s license. The trooper noticed that the car’s open console contained loose money and a prescription bottle with the label removed. The trooper asked Ruckes to step out of the car, and patted him down. After discovering that Ruckes’s license had been suspended, he searched the vehicle, finding drugs and a weapon. Ruckes appealed the denial of his suppression motion, arguing that the trooper’s search of his car was not incident to arrest because he was not arrested until after the contraband was found within the vehicle. The appellate court upheld the search, finding that the trooper was authorized to both impound and inventory a vehicle when its operator is arrested for driving on a suspended license. Ruckes’s loaded pistol and crack cocaine would have inevitably been discovered even though the search incident to arrest was invalid. Therefore, the evidence was properly admitted under the inevitable-discovery exception to the exclusionary rule.