A blog of the Philadelphia Bar Association’s Criminal Justice Section


By Burt Rose

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In Com. v. Gatlos2014 EDA 2012, 2013 WL 4804836 (Pa.Super., September 10, 2013), the court 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. While an inventory search must be conducted pursuant to reasonable police procedures, in good faith, and not as a substitute for a warrantless investigatory search, an inventory search, undertaken to ascertain Appellant’s identity, motivated not by investigative efforts of police, but by the trooper’s intent to protect Appellant’s life, is lawful. Here, the inventory search for Appellant’s identity was conducted pursuant to standard police procedure, in a good faith attempt to identify Appellant, who was unconscious and in immediate need of medical assistance. Thus the marijuana that was found in the car was admissible at the trial.


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