Ya’ Don’t Know if Ya’ Didn’t Look!

By Randall C. Resch

I’ve archived as many as 136 individuals who were discovered in towed vehicles as result of violence, homicide, PPIs, and other reasons. Discovered alive were four accident victims, 15 sleeping children, and two kidnapped victims, which were not discovered by Law Enforcement, EMS, or towers. It happens more than you think!

Unoccupied vehicles have a likeness to Tupperware. Everyone knows that Tupperware are sealable containers that keep products fresh for days. But sealable containers don’t keep products fresh for long periods of time. And when tupperware is exposed to heat environments, the contents within spoil in a matter of time. Same can be said for the contents inside vehicle interiors.

Recently, two bodies were found in towed vehicles at the same San Diego tow yard four months apart.

Case One: A Month Too Late

In the first case, a 65-year-old female, reportedly homeless, was discovered deceased nearly a month after her vehicle was towed. She allegedly was living inside a Honda Odyssey van, parked curbside on city streets when the van was struck by a DUI motorist.  A lawsuit alleges she was “visible to anyone looking inside,” but lawsuits often allege more than can be proven. Was she clearly visible at the time of the tow? It's hard to say—and harder to defend.

Case Two: A Missed Opportunity

Four months later, a city parking officer cited a Kia for sitting too long. No entry was made. Two weeks later, the car was impounded. When a lien notice reached the family, they filed a missing person report. Detectives visited the tow yard and found the person deceased inside.

Should this have been preventable?

Legal, Moral, Ethical Questions

When it comes to vehicle searches and inventories, law enforcement agencies often follow their own internal policies. According to the Federal Law Enforcement Training Center’s (FLETC) Standard Operating Procedures Manual, under the section “Searching Vehicles Without Warrants,” officers may conduct inventory searches of vehicles in their custody without a warrant, as long as the search follows a reasonable and standardized policy.

Specifically, the manual states:

“A vehicle that has fallen under the custody of law enforcement officers may be inventoried, if done pursuant to a reasonable standardized policy. Neither reasonable suspicion nor probable cause is required.”

The purpose of these inventory searches is to: 1. Protect the vehicle owner’s property1. Protect the vehicle owner’s property2. Protect law enforcement from false claims of lost or stolen items2. Protect law enforcement from false claims of lost or stolen items3. Identify any potential dangers (e.g., weapons, hazardous materials)3. Identify any potential dangers (e.g., weapons, hazardous materials)

This same reasoning applies to tow operators once a vehicle is in their custody. If a claim of theft or missing property arises after a tow, a documented inventory can protect the towing company as well.

That raises a key question: At what point should a policy kick in? And who is responsible for performing the inventory? From my Street Cop Days

Back when I was a street cop, policy required us to conduct a cursory search and list vehicle contents before a tow. That meant unlocking cars and scanning for valuables or contraband. While we rarely opened trunks without cause, checking interiors often revealed what needed attention—sometimes even a body. Talking Facts or Making Excuses?

In the second case from April 2025, a San Diego Police Department lieutenant told reporters:

“The body of the man discovered at the tow yard may have been detected sooner had the vehicle not been locked.”

This raises a valid question: What is the department’s policy regarding inventory searches for routine street impounds—those not tied to violent crimes? Shouldn’t law enforcement be responsible for conducting a pre-tow inventory of all vehicles being impounded?

There are several reasons often cited for why these searches aren’t consistently performed: -- Does state law require a warrant to search a vehicle in non-criminal situations?-- Does state law require a warrant to search a vehicle in non-criminal situations?-- Do extreme weather conditions discourage thorough searches?-- Do extreme weather conditions discourage thorough searches?-- Are there gaps in agency policies that don’t mandate inventory in routine field impounds?-- Are there gaps in agency policies that don’t mandate inventory in routine field impounds?-- Are officers skipping inventories due to high call volume or time constraints?-- Are officers skipping inventories due to high call volume or time constraints?-- Does dark window tint make interior inspection too difficult?-- Does dark window tint make interior inspection too difficult?-- Or, bluntly—are some personnel simply too indifferent to look inside?-- Or, bluntly—are some personnel simply too indifferent to look inside?

Whether these are facts or excuses depends on the context—but lives may depend on the answer.

In another news segment, the same SDPD lieutenant said:

“They would do an inventory search of the vehicle for any valuables inside. As was noted in this report, they were not able to gain access to the vehicle to conduct that inventory search.”

But that begs the question: If access had been authorized or attempted, could the victim have been discovered sooner?

Had there been an authorized order to unlock, would the victim have been found in time?

Legally, conducting searches is not the responsibility of tow operators. However, tow companies should seriously consider at least visually inspecting vehicle interiors—not only as a matter of due diligence, but also to avoid being named as a defendant in cases like these.

In the end, it comes down to one question: Did anyone look inside?