The following excerpt is from U.S. v. Malcolm, 891 F.2d 296 (9th Cir. 1989):
Because we have found that there was probable cause for the search of the vehicle, we do not determine whether the district court was correct in concluding that exigent circumstances justified the search of the vehicle or whether the officers conducted a proper inventory search. See United States v. Feldman, 788 F.2d at 553 n. 11. (in upholding the validity of an inventory search, "we need not reach the government's alternative justifications for the search").