United States v. Vick – First Circuit Narrows the “Sole-Investigatory-Motive” Test in Community-Caretaking Impoundments & Inventory Searches

Introduction

In United States v. Vick, No. 24-1721 (1st Cir. July 30, 2025), the Court of Appeals for the First Circuit reversed a district-court order suppressing a firearm discovered during an inventory search. The panel (Chief Judge Barron, Judges Gelpí and Rikelman, opinion by Judge Rikelman) addressed the recurring Fourth-Amendment puzzle of when police may impound a vehicle and later inventory its contents without a warrant.

The district court had suppressed the gun, finding police “staged” the impound and that their “sole motive” was investigative. On appeal, the government argued (i) subjective motives are irrelevant if objective criteria are met, and (ii) in any event the record could not sustain a “sole-investigatory-motive” finding. The First Circuit agreed on the latter, announcing a clarifying rule: suppression is warranted only if investigatory intent is truly the exclusive (“sole”) driver of the impoundment or inventory search, and mere policy deviations or mixed motives will not suffice.

Key Holding: Where officers possess an objectively reasonable community-caretaking basis to impound a vehicle, and at least one caretaking purpose in fact motivates them, evidence uncovered in the ensuing inventory search is admissible—even if the officers harbor a strong concomitant investigative purpose and deviate in non-essential ways from departmental policy.

Summary of the Judgment

Objective Reasonableness Conceded: Defendant conceded the Altima was unregistered, uninsured, and displaying wrong plates—facts that made impoundment objectively reasonable under MSP’s Towing Policy and community-caretaking caselaw.
District Court’s Error: The trial court nonetheless suppressed the gun, deeming the officers’ sole motivation investigatory.
Appellate Reversal: The First Circuit held that finding clearly erroneous because (a) the record showed genuine safety concerns, and (b) any policy deviations (e.g., not asking for preferred tow company) did not transform mixed motives into an exclusively investigative one.
Inventory Search Upheld: Even assuming “material” deviations from MSP’s Inventory Policy, the caretaking purpose remained, foreclosing suppression.
Disposition: Suppression order reversed; case remanded for further proceedings.

Analysis

Precedents Cited & Their Influence

The Court weaves a dense tapestry of Supreme Court and First-Circuit authority:

Cady v. Dombrowski, 413 U.S. 433 (1973) – Origin of the community-caretaking doctrine; police may act without warrant to mitigate public-safety hazards.
South Dakota v. Opperman, 428 U.S. 364 (1976) – Validated warrantless inventory searches if done pursuant to standardized criteria.
Colorado v. Bertine, 479 U.S. 367 (1987) – Officers must act in good faith; inventory searches must follow policy.
Florida v. Wells, 495 U.S. 1 (1990) – An inventory search deployed as investigative ruse violates the Fourth Amendment.
United States v. Del Rosario, 968 F.3d 123 (1st Cir. 2020) – Suppression warranted where no objective caretaking justification existed.
United States v. Sylvester, 993 F.3d 16 (1st Cir. 2021) – Mixed motives permissible; officers need not choose least intrusive caretaking method.
United States v. Rivera, 988 F.3d 579 (1st Cir. 2021) – Reaffirmed need for standardized inventory procedures.

By distinguishing Del Rosario and amplifying Sylvester, the Vick panel effectively narrows situations where subjective intent will vitiate an otherwise valid caretaking impoundment.

Legal Reasoning

Step One – Objective Reasonableness. Because the car could not lawfully be driven, public-safety concerns fit squarely within MSP’s Towing Policy and community-caretaking doctrine. Defendant’s concession removed dispute.
Step Two – Subjective Intent Inquiry. Even if officers’ motives matter, only an exclusive investigatory motive triggers suppression. Record evidence (unregistered vehicle, unlicensed driver with child, officer testimony) created undeniable caretaking purpose.
Step Three – Policy Deviations. Deviations are relevant only if (i) material and (ii) support an inference of pretext. Here, failing to ask Warner for a tow-company preference was immaterial because no legal driver or valid plates existed; listing items generically (“speaker box,” etc.) did not show pretext given immediate discovery of contraband and completion of inventory form.
Step Four – Inventory Search Validity. Once impoundment was legal, MSP policy compelled an inventory search. Mixed motives again tolerated; caretaking objective satisfied the Fourth Amendment.

Impact on Future Cases & the Law

Higher Evidentiary Burden for Defendants. Defendants must now produce clear, affirmative evidence that police were solely investigative—mere strong suspicion or policy imperfections insufficient.
Guidance to Trial Courts. Before delving into subjective intent, courts must (i) decide objective reasonableness of impoundment and (ii) ascertain whether any caretaking motive existed.
Policy-Deviation Doctrine Clarified. Minor or practical departures from inventory rules will rarely justify suppression absent proof of deliberate pretext.
Law-Enforcement Training. Agencies may revisit towing/inventory procedures to minimize deviations; yet the ruling affords officers leeway in fast-moving scenarios.
Potential Circuit Split. The Ninth Circuit (see United States v. Johnson, 889 F.3d 1120) embraces a more rigorous pretext analysis; Vick may thus invite Supreme Court review to harmonize approaches.

Complex Concepts Simplified

Community-Caretaking Exception: Allows police to act without a warrant when performing non-investigative duties—e.g., removing hazards, aiding motorists, securing property.
Impoundment vs. Inventory Search: Impoundment is seizing/moving a vehicle; inventory search is the administrative cataloging of property for safekeeping and liability avoidance.
“Sole-Investigatory-Motive” Test: Suppression applies only if evidence shows officers acted exclusively to gather evidence, with no genuine caretaking rationale.
Objective vs. Subjective Inquiry: Objective: Would a reasonable officer perceive a safety need to impound? Subjective: What actually motivated these officers?
Standardized Procedures Requirement: Departments must have and generally follow written policies; their existence guards against rummaging for evidence.

Conclusion

United States v. Vick reshapes First-Circuit Fourth-Amendment jurisprudence by tightening the standard for invalidating impoundment-based inventory searches. The decision underscores three takeaways:

Courts must first examine objective reasonableness; conceded or established safety concerns severely limit suppression prospects.
Mixed motives do not doom a search; only a truly exclusive investigatory purpose will suffice, and defendants bear a heavy evidentiary load to prove it.
Policy deviations matter only if they demonstrably signal pretext; minor or practical lapses will not undo otherwise lawful searches.

Practitioners should heed the Court’s emphasis on concrete facts and the difficulty of proving sole investigatory motive. Vick thus marks a significant clarification—if not contraction—of the pretext doctrine in the context of vehicle impoundments and inventory searches, reinforcing officers’ caretaking discretion while preserving safeguards against sham inventories.