The appellant was arrested for possession of narcotics.
Hours later, an RCMP officer conducted a warrantless inventory search of the appellant's impounded car pursuant to police policy, discovering cash and cocaine.
The Supreme Court of Canada held that the search violated section 8 of the Charter because an inventory search is not a valid objective of the common law power of search incident to arrest, and thus the search was not authorized by law.
However, applying the Collins test under section 24(2) of the Charter, the Court concluded that the non-conscriptive evidence should not be excluded, as the breach was not serious and exclusion would have a more detrimental impact on the administration of justice.
