Facts
After working an eight-hour shift in 2003, Detective Denise McMullen of the Meridian Police Department attempted to serve a felony warrant on Billy Ray Bradley. She received an anonymous tip as to Bradley’s location but received a subsequent tip that Bradley was near the North Frontage Road in Meridian.
McMullen spotted Bradley, carrying a tan suitcase, along with his girlfriend, Leslie Grady, on the frontage road and contacted the backup officers. Officers William Brunelle and Ron Brooks arrived on the scene and instructed Bradley to drop his suitcase and place his hands on the police car. Detective McMullen then approached and advised Bradley that he was under arrest.
McMullen then read Bradley his Miranda warnings, and Bradley was escorted to the station in a patrol car. The suitcase and Grady were also taken to the station. While inventorying Bradley’s possessions at the station, the police found .22 caliber bullets in Bradley’s pocket. Inside the suitcase Brunelle found, among other things, a VCR with a tape partially ejected.
Brunelle testified that the VCR rattled, as though it were broken. Brunelle asked Bradley if the VCR worked, and as Brunelle removed the tape, he discovered a pistol wedged inside the VCR. Bradley initially denied any knowledge of the gun, but Bradley later admitted that he was holding the gun for a friend.
Bradley was convicted of being a felon in possession of a firearm and sentenced to life as a habitual offender. On appeal, he argued the search of his bag was improper. MCOA affirmed.
Analysis
Bradley’s suitcase was searched as part of a police inventory — a matter of police procedure which allows the police to properly account for and preserve items belonging to the arrestee. See Robinson v. State, 418 So.2d 749 (Miss. 1982). Items seized pursuant to this routine police procedure are admissible.
Brunelle testified that they discovered the gun when they inventoried the suitcase. Brunelle also testified that they conducted the inventory search in Bradley’s presence as a matter of police procedure. We find that the evidence secured from the suitcase was the result of an inventory search; thus, no warrant was necessary.