5.8.1

• Jurisdiction: Arizona

§ 5.8.1 Inventory Search – Person

1. General Rule. Incident to incarceration, the personal effects (any container or article) of an individual may be inventoried. Illinois v. Lafayette, 462 U.S. 640 (1983); State v. Stukes, 151 Ariz. 216, 726 P.2d 632 (1986). A discussion of this inventory rule is located in State v. Paxton, 186 Ariz. 580, 925 P.2d 721 (App. 1996) (Div. 1) (bloodstains on defendant’s shoes would have been discovered in jail inventory search). The taking of property that is evidence of a crime from a defendant’s possession “is a normal incident of a custodial arrest.” United States v. Edwards, 415 U.S. 800, 805 (1974) (search of the arrestee’s clothes was lawful even though it was not contemporaneous with the arrest; officers may conduct a lawful search without a warrant “where the...