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Officer Chen stopped Dana for speeding. During the stop, Chen smelled burnt marijuana coming from the car and saw a small bag of white powder on the passenger seat. Chen ordered Dana out of the car, arrested her for driving with a suspended license after a records check, handcuffed her, and placed her in the patrol car.
Chen then searched the passenger compartment, opened the glove box, and found a scale. In the trunk, Chen found a locked backpack. He pried it open and found cocaine. On the driver's seat, Chen also found Dana's smartphone. Without a warrant, he opened the phone and searched recent messages, finding texts about drug sales. The department later claimed the entire search was valid as an inventory search because Dana's car was towed, although Chen had not followed the department's written inventory checklist.
Dana moves to suppress the scale, cocaine, and phone messages. Analyze the possible justifications for each search or seizure.