Kruchek does not offend the aim of clarity underlying the per se nature of the automobile exception. By contrast, the rule of constructive impoundment advocated by defendant would return police to the complex task of legal fact-matching under dynamic field conditions that the court in Brown sought to avoid. Further, defendant’s theory cannot be reconciled with results in Brown and Kosta that were based on circumstances comparable to those found here. Unlike in Kruchek, there is no evidence that, when the search of defendant’s backpack occurred, the car was impounded or that the investigating officers had arranged for it to be towed. vehicle when first encountered by police are not germane to our decision in this case. See, e.g., State v. Kock, 302 Or 29, 33, 725 P2d 1285 (1986) (<HOLDING>). 4 We consistently have followed Kruchek in
holding that parked police vehicle could not constitute other traffic holding on direct review that defendant was not in custody when he was interviewed by law enforcement officers in a parked police vehicle which was unmarked and unlocked holding automobile exception applied to shotgun seized from trunk of vehicle parked at defendants home holding automobile exeeption did not apply to warrantless search of vehicle where vehicle was not readily mobile because the vehicle was legally parked in parking lot occupants of vehicle were seated on a bench in the playground near the parking lot police officers surrounded the vehicle and the driver of the vehicle was handcuffed for safety purposes holding that the automobile exception does not apply to a vehicle that is parked immobile and unoccupied when police encounter it