The author questions the decision on two grounds: that it does not adequately resolve the split in the circuit courts over how to apply precedent to inventory search cases and that, in its next inventory search case, the Court will decide to grant the police a measure of discretion in determining the scope of such searches. In other words, the Court will change the law to conform to the dicta in Wells. The author feels this decision signals the Court's willingness to exclude less evidence by granting the police more discretion to open closed containers. However, a new law along these lines would probably not have the desired effect on the amount of evidence actually admitted by the courts. 155 notes