People v. Spencer 

Defendant was convicted, after jury trial, of possession of a controlled substance with intent to deliver. Defendant had pulled his car into school parking lot upon being stopped and arrested for pandering. State failed to establish that impoundment of vehicle was lawful, which is threshold requirement for lawful inventory search. State did not show that vehicle was not legally parked, that parking was prohibited, or that vehicle was impeding traffic or endangering the public. Search of Defendant's car, which was made pursuant to police department policy that an arrested person's vehicle shall be towed, violated Fourth Amendment, and thus motion to suppress cocaine found in lock box in trunk of car should have been granted. (LAVIN and PUCINSKI, concurring.)