Snitko v. United States

FBI's inventory searches of safe deposit boxes seized pursuant to warrant from self-storage facility that government was investigating for various criminal activities, including money laundering, did not fall within scope of inventory search exception to warrant requirement, even though FBI had standardized inventory search policy, where FBI conducted inventory searches pursuant to supplemental instructions designed specifically for facility; government exceeded scope of warrant authorizing seizure of safe deposit boxes from self-storage facility; warrant specifically did not authorize criminal search or seizure of boxes' contents, investigating agents fully expected there to be criminal customers at facility and anticipated there would be criminal proceeds in boxes, government policy required agents to obtain warrants if they came across evidence of criminality during inventory searches or expected inventory search to yield contraband, and government failed to obtain warrants or to notify box renters of seizures upon discovering their contact information inside boxes.