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No Warrant Needed for Inventory Search of Unresponsive Crash Victim’s Vehicle

Posted On: September 25, 2013 by Marc Neff

Danielle Gatlos was involved in a motor vehicle accident in Pennsylvania. When the police arrived on the scene, she was unconscious and unresponsive. The officers went into Danielle Gatlos’ vehicle and handbag to obtain her identity and to inventory her belongings. During this investigation, the police discovered marijuana. Danielle was eventually charged with possession of marijuana and DUI. Before trial, a motion to suppress the physical evidence was presented to the court where the defense attorney argued that the evidence was obtained illegally and violated the constitutional protections afforded to individuals against illegal search and seizures.

The Court denied the motion to suppress the physical evidence and held that the police may conduct a warrantless inventory search of a vehicle for the purpose of identifying an unresponsive and otherwise unidentifiable crash victim. The court explained that an inventory search must be conducted pursuant to reasonable police procedures, in good faith, and not as a substitute for a warrantless investigatory search. Here, the inventory search for the victim’s identity was conducted pursuant to standard police procedure, in a good faith attempt to identify the victim, who was unconscious and in immediate need of medical assistance. Thus the marijuana that was found in the car was admissible at the trial.


All persons charged with crimes are entitled to the protections afforded by the United States Constitution and the rules of evidence in a criminal court of law. An experienced criminal defense attorney helps to ensure that a defendant’s rights are protected before, during and after a trial. If you have been charged with or convicted of a criminal offense, you should consult with a criminal defense attorney immediately. For a confidential consultation, contact the Law Offices of Marc Neff at (215) 563-9800 or via email at marc@nefflawoffices.com.

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Posted in: Drug Crimes