State of Minnesota, Respondent v. Steven Allen Gauster, Appellant

Summary

The court held that police unlawfully impounded Gauster’s vehicle because he was not arrested, the vehicle did not pose a safety hazard, and he was available and willing to make reasonable arrangements for its custody or removal. Because the impoundment was unjustified, the resulting inventory search violated the Fourth Amendment, requiring suppression of the evidence and dismissal of the charges. The court also held that the State waived its alternative automobile-exception argument because it was raised for the first time on appeal and the factual record was insufficient.