Does a police department's policy sufficiently limit officer discretion during an inventory search if it enables an officer to choose to open a closed container based on the prospect that incriminating evidence may be found inside?

QUESTION PRESENTED In Florida v. Wells, 495 U.S. 1 (1990), this Court held that a warrantless search of a closed container found in an impounded vehicle is permissible under the inventory search exception to the Fourth Amendment’s warrant requirement only if the search is conducted pursuant to “standardized criteria” that sufficiently limit a searching officer’s discretion to open the closed container. Id. at 4. The Court explained that officer discretion must be limited to ensure that the “inventory search’ is not “a ruse for a general rummaging in order to discover incriminating evidence.” Id. The question presented is: Does a police department’s policy sufficiently limit officer discretion during an inventory search if it enables an officer to choose to open a closed container based on the prospect that incriminating evidence may be found inside?