What requirement was established in Florida v. Wells regarding inventorying closed containers?

In Florida v. Wells, the Supreme Court established that law enforcement agencies must have a written policy regarding the inventorying of closed containers found during vehicle impounds. This requirement is rooted in the need to protect the Fourth Amendment rights of individuals against unreasonable searches and seizures. A written policy helps ensure that officers adhere to consistent procedures, which can reduce the potential for arbitrary decision-making and protect against claims of improper search or mishandling of personal property.

Having a documented policy is essential because it provides clear guidance on how closed containers should be treated during an inventory search. This also establishes accountability within the law enforcement agency, ensuring that officers follow established protocols and that there is transparency in their actions. A well-defined written policy helps demonstrate that the agency's inventory practice is standardized and not based solely on individual officer discretion.