In People v. Douglas, the Court of Appeals recently addressed the constitutionality of the New York City Police Department’s (N.Y.P.D.) protocol for inventory searches of vehicles, which represent one of the exceptions to the general rule that police must obtain a warrant before conducting a search.

The defendant was stopped by two N.Y.P.D. officers in October 2015 for several traffic violations. The officers discovered an illegal gravity knife in the defendant’s pocket, arrested him, impounded his vehicle, and took him and his vehicle to the local precinct. The police officers conducted an inventory search of the vehicle in the precinct parking lot and recovered a firearm from the trunk.