Fourth Amendment-Inventory Search Exception

7^th Circuit Court of Appeals

Case Name: United States of America v. William Fillyaw

Case No.: 25-1836

Officials: Scudder, Kirsch, and Taibleson, Circuit Judges.

Focus: Fourth Amendment-Inventory Search Exception

The Law enforcement officers arrested Fillyaw in a public parking lot pursuant to a warrant arising from allegations of arson. At the time of the arrest, Fillyaw was carrying a backpack. After taking him into custody, officers seized the backpack and searched it several minutes later, discovering a loaded handgun and narcotics. Fillyaw was subsequently charged with federal criminal offenses.

Fillyaw moved to suppress the evidence recovered from the backpack in the Northern District of Illinois, Eastern Division, arguing that the search violated the Fourth Amendment. The district court denied the motion, concluding that the search was valid under the inventory-search exception to the warrant requirement. The defendant later entered a guilty plea while preserving his right to challenge the suppression ruling on appeal.

The Seventh Circuit considered whether the warrantless search of the backpack was constitutionally permissible. The court explained that law enforcement officers may assume custody of an arrestee’s personal belongings when the arrest occurs in a public place and may conduct an inventory search pursuant to standardized procedures. Although Fillyaw identified minor departures from departmental policy in the execution and documentation of the search, the court determined that those deviations did not render the search unreasonable under the Fourth Amendment. The court also rejected his contention that the officers acted in bad faith, finding no evidence in the record to support that claim. In addition, the court declined to address his challenge to law enforcement’s use of a license plate reader database because the issue had not been properly raised before the district court and was therefore forfeited.

Decided 05/26/26

Full Text