Promising Case About the Seizure of Locked, Anonymous Safe Deposit Boxes Doesn’t Reveal Much

By Robert Phillips  
Deputy District Attorney (ret.)  

Warrantless searches and seizure of anonymous safe deposit boxes violate the Fourth Amendment absent probable cause, and cannot be justified as an inventory search. 

The Ninth Circuit Court of Appeal recently decided the potentially interesting — even if a bit confusing — case of Snitko v. United States (9th Cir. Jan 23, 2024) F.4th [2024 U.S. App. LEXIS 1484].  

This case involves an FBI investigation, assisted by the DEA and the United States Postal Inspection Service (or USPIS — I had to Google what this abbreviation stood for) of a Beverly Hills company named US Private Vaults (USPV).  

It seems that USPV is (or perhaps, after this case, was) a business that rented out completely confidential safe deposit boxes (700 of them; consistently referred to by the court as the company’s “nests of safe deposit boxes”) to people who could— and would — remain anonymous. USPV’s customers were to keep all keys to the boxes. More significantly, USPV’s facility featured significant security measures, including iris-scan vault access, 24/7 electronic monitoring, 24/7 armed response, and a time lock on the vault itself. Protection of its customers’ anonymity was USPV’s main selling point, advertising on its website that clients could rent their safe deposit boxes anonymously, that the company didn’t even want to know who a prospective renter was, and that the company “would only cooperate with the government under court order.”  

This piqued the interest of the FBI, concluding that what USPV was really doing was giving dope dealers somewhere to hide their proceeds and/or profits (or even their dope), and that as such, they were likely laundering illegal narcotics profits. The FBI, therefore, seeking a criminal indictment of USPV, put together an affidavit for a search warrant asking the trial court to allow them to seize and inventory the contents of all 700 of USPV’s safe deposit boxes. 

Recognizing, however, that they likely lacked probable cause justifying such a warrant, particularly knowing that not all box renters would be involved in criminal activity, the FBI attempted to ....

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