Was the second warrantless search of the car -which followed the completed inventory search and was prompted by an officer's later-developed suspicions -an impermissible warrantless search in violation of the Fourth Amendment?

Questions Presented Although an officer’s subjective intentions are irrelevant when a search is based on probable cause to arrest, this Court has “expressly distinguished cases where we had addressed the validity of searches conducted in the absence of probable cause,” like inventory searches. Indianapolis v. Edmond, 531 U.S. 32, 45 (2000) (citing Whren v. United States, 517 U.S. 806, 810-13 (1996) (distinguishing inventory searches from warrantless searches based on probable cause to arrest)). But this Court also stated that, in the context of programmatic searches and seizures, like inventory searches, the Fourth Amendment inquiry has “nothing to do with discerning the mind of the individual officer,” but is directed at “ensuring that the purpose behind the program is not ‘ultimately indistinguishable from the general interest in crime control.’” Brigham City v. Stuart, 547 U.S. 398, 405 (2006) (emphasis in original). The Court of Appeals, in this case, relied on Brigham City. However, Brigham City was not an inventory-search case, but a warrantless arrest in a person’s home, based on exigent circumstances. And this Court later indicated, again, that in the context of inventory searches, an officer’s improper motive can invalidate such a search under the Fourth Amendment. Kentucky v. King, 563 U.S. 452, 464 (2011). Here, Petitioner was arrested principally for traffic i violations and taken to a precinct. The police then conducted an inventory search of the rental car he had been driving, finding property, but nothing illegal. The officers then started processing the arrest, intending to release him on a “desk appearance ticket.” And he was allowed to make a phone call. An officer overheard Williams’s conversation, became suspicious, and conferred with other officers. Prompted by this suspicion, he and other officers then searched the car a second time, without bothering with a warrant. Forcibly pulling open a console panel in the car, not designed to open, they found a gun. The district court and the Court of Appeals held that the second search was simply an inventory search, regardless of the officers’s reasons for conducting the second search. Question One: Was the second warrantless search of the car -which followed the completed inventory search and was prompted by an officer’s later-developed suspicions -an impermissible warrantless search in violation of the Fourth Amendment? Question Two: Under Rehaif v. United States, 139 S.Ct. 2191 (2019), should Petitioner’s conviction of possessing a firearm while being a prohibited person, in violation of 18 U.S.C. § 922(g), be vacated? di