In an opinion drafted by Justice Hardesty, the Nevada Supreme Court considered whether the search of an individual’s belongings is beyond the scope of a permissible search incident to arrest when the search occurs after the individual is safely under the control of officers, and whether the inevitable-discovery doctrine applies when a booking officer fails to produce any written inventory detailing the contents of an arrestee’s belongings. The Court held that searching an individual’s belongings after that individual is already in custody is not a valid search incident to arrest, and that the inevitable-discovery doctrine does not apply when a booking officer fails to produce written inventory detailing the contents of the arrestee’s belongings.
Phipps, Jessica, "State v. Nye, 136 Nev. Adv. Op. 48 (July 30, 2020)" (2020). Nevada Supreme Court Summaries. 1329.