(11th Cir. 1983). The government must establish, first, that the officers had the
authority to impound the defendant’s vehicle, and second, that the officers
complied with departmental policy in conducting the search. United States v.
Williams, 936 F.2d 1243, 1248 (11th Cir. 1991).
An officer’s failure to complete a written inventory form does not
necessarily invalidate an inventory search. See United States v. O’Bryant, 775
F.2d 1528, 1534 (11th Cir. 1985) (concluding that the searching officer’s failure to
complete a written inventory did not render the search of the defendant’s briefcase
unreasonable). The Fifth Circuit addressed a factual situation similar to this case
in United States v. Loaiza-Marin, 832 F.2d 867 (5th Cir. 1987). In Loaiza-Marin,
a border patrol agent conducted an inventory search of the defendant’s suitcase
and discovered that it contained bags of cocaine. Id. at 868. The agent then
turned the defendant and the drugs over to the Drug Enforcement Administration
(“DEA”). Id. The Fifth Circuit held that the border patrol agent’s failure to
complete a written inventory form, as required by Border Patrol policy, did not
render the search unreasonable because the agent had turned the evidence over to
DEA agents, and, therefore, the agent had no reason to complete the inventory
form. Id. at 869.
In this case, the district court did not clearly err in finding that the impound