Officers are allowed “some latitude and exercise of judgment,” as long as “those decisions are based on concerns related to the purposes of an [inventory search].” Id. (quotations omitted). That the Policy allows some discretion as to whether to treat a case as an in-custody arrest tow or a private-property tow does not make the inventory search unconstitutional. Likewise, regarding Hall’s other arguments, the minimal discretion afforded searching officers is not constitutionally significant. B. Compliance with the Poliey/Bad Faith Hall next argues Officer Kasper violated the Fourth Amendment by conducting the inventory search in bad faith, as evidenced by his failure to comply with the Policy in several respects. See, e.g., United States v. Rowland, 341 F.3d 774, 780 (8th Cir.2003) (<HOLDING>). The district court found that the searching
holding a county police civil service board violated officers due process rights by failing to follow its own procedures in their termination proceedings holding the evidence supported the police officers failure to follow the directives in the montgomery county police departments field operations manual holding that officers action of putting suspects on the ground and searching for weapons was within the scope of a terry stop holding that the searching officers failed to follow the departments own procedures by failing to make a record of all property within the inventoried vehicle holding that fire departments are analogous to police departments in this respect