Search incidents to arrest Flashcards
Chimel v. California
Facts
In the case of Chimel v. California, the Supreme Court was presented with questions regarding the permissible scope under the Fourth Amendment of a search incident to a lawful arrest.
On September 13, 1965, police officers arrived at Ted Chimel’s home with an arrest warrant for burglary. Despite Chimel’s objections and without a search warrant, officers conducted a thorough search of his entire house, including the attic, garage, and workshop. They directed Chimel’s wife to assist in the search of drawers and seized numerous items related to the burglary. The items were used as evidence in Chimel’s burglary trial, leading to his conviction. Both the California Court of Appeal and the California Supreme Court affirmed the conviction, justifying the search as incident to a lawful arrest despite the absence of a search warrant.
Issue
The primary legal issue was whether the warrantless search of Chimel’s entire house could be constitutionally justified as incident to his lawful arrest, especially in light of the Fourth Amendment’s protections against unreasonable searches and seizures.
Holding
The Supreme Court reversed Chimel’s conviction, holding that the search of his entire house without a search warrant was “unreasonable” under the Fourth and Fourteenth Amendments. The Court established that the scope of a search incident to a lawful arrest must be limited to the arrestee’s person and the area within his immediate control, where it is possible to obtain either a weapon or evidence that might be destroyed.
United States v. Robinson
Facts
United States v. Robinson involved the respondent, Robinson, who was convicted in the United States District Court for the District of Columbia for possession and facilitation of concealment of heroin.
The arrest occurred on April 23, 1968, when Officer Richard Jenks of the Metropolitan Police Department observed Robinson driving a car and, knowing Robinson’s operator’s permit had been revoked, stopped him for the offense. Upon arresting Robinson, Jenks conducted a search and found a crumpled cigarette package in Robinson’s coat pocket, which contained heroin. This evidence led to Robinson’s conviction.
The case was appealed to the Court of Appeals for the District of Columbia Circuit, which reversed the conviction, ruling the search unconstitutional under the Fourth Amendment. The Supreme Court granted certiorari to review the case.
Issue
The central legal issue in United States v. Robinson was whether the search of Robinson, incident to a lawful custodial arrest for a traffic offense, violated the Fourth Amendment’s prohibition against unreasonable searches and seizures.
Holding
The Supreme Court reversed the judgment of the Court of Appeals, holding that the search of Robinson incident to his lawful arrest did not violate the Fourth Amendment. The Court affirmed that a full search of a person is a reasonable and lawful action following a lawful custodial arrest.
Vale v. Louisiana
Facts
Donald Vale was convicted in Louisiana for possessing heroin, with a 15-year sentence at hard labor. His conviction was affirmed by the Louisiana Supreme Court, which rejected his argument that the conviction was based on evidence from an unlawful search and seizure. Vale appealed, challenging the legality of the search of his residence where narcotics were found. The police had arrest warrants for Vale and surveilled his home, witnessing activities they believed indicated a narcotics transaction. After observing Vale and another individual in suspicious behavior, the police arrested Vale and searched his house without a warrant, finding narcotics.
Issue
The central issue in this case is whether the warrantless search of Vale’s home, conducted immediately following his arrest outside the home, violated the Fourth Amendment, which protects against unreasonable searches and seizures.
Holding
The U.S. Supreme Court reversed the Louisiana Supreme Court’s decision, holding that the warrantless search of Vale’s home was unconstitutional. The search was neither substantially contemporaneous with the arrest nor confined to the immediate vicinity of the arrest, failing to meet the criteria necessary for a search incident to an arrest.
New York v. Belton
Facts
On April 9, 1978, Trooper Douglas Nicot, after a car chase on the New York Thruway due to excessive speeding, stopped a vehicle containing four men, including Roger Belton. None of the men owned the vehicle or were related to its owner. The trooper smelled burnt marijuana and saw a “Supergold” envelope, which he associated with marijuana, on the car floor. After placing the men under arrest for the unlawful possession of marijuana, searching them, and giving them Miranda warnings, Trooper Nicot searched the passenger compartment of the car. In the back seat, he found a leather jacket belonging to Belton, which upon searching, yielded cocaine. Belton was indicted, moved to suppress the cocaine as evidence claiming Fourth and Fourteenth Amendments violations, but was denied. His conviction was upheld by the appellate division but reversed by the New York Court of Appeals, which held the search unconstitutional since the jacket was not accessible at the time of the search.
Issue
The central issue is whether, in the context of a lawful custodial arrest of the occupant of an automobile, the Fourth Amendment permits the search of the passenger compartment of the vehicle and any containers found therein.
Holding
The Supreme Court reversed the New York Court of Appeals, holding that after a lawful custodial arrest of the occupant of a vehicle, the police may search the vehicle’s passenger compartment and any containers found within as a contemporaneous incident of that arres
Arizona v. Gant
Facts
Rodney Gant was arrested by Tucson police officers for driving with a suspended license. After being handcuffed and placed in a patrol car, officers searched his vehicle and found cocaine in the pocket of a jacket on the backseat. Gant moved to suppress the evidence, arguing the search was unconstitutional because he was not in a position to access his vehicle to retrieve weapons or evidence at the time of the search. The trial court denied the motion to suppress, and Gant was convicted of drug offenses. The Arizona Supreme Court reversed, holding the search was unreasonable because it did not meet the justifications of officer safety or evidence preservation under Chimel v. California.
Issue
The issue before the Supreme Court was whether police officers are permitted to search the passenger compartment of a vehicle incident to the arrest of a recent occupant when the arrestee is secured and not within reaching distance of the vehicle, and there is no evidence to suggest that the crime for which the person was arrested could be connected to evidence in the vehicle.
Holding
The Supreme Court held that police may search the passenger compartment of a vehicle incident to a recent occupant’s arrest only if it is reasonable to believe the arrestee might access the vehicle at the time of the search or that the vehicle contains evidence of the offense of arrest. The Court affirmed the decision of the Arizona Supreme Court, finding the search unreasonable under the Fourth Amendment.
Riley v. California
Facts
In Riley v. California, the Supreme Court consolidated two cases involving the warrantless search of cell phones by police officers following an arrest. In the first case, David Riley was stopped for a traffic violation, which led to his arrest for firearms offenses after the police found guns in his car. Upon arrest, officers searched Riley’s smartphone without a warrant, finding evidence linking him to gang activities and an earlier shooting. Riley moved to suppress the evidence from his phone, arguing that the search violated the Fourth Amendment, but the trial court denied the motion, and he was convicted. In the second case, Brima Wurie was arrested for suspected drug sales. Police searched his flip phone without a warrant, using the call log to trace and search a house where they found drugs and a gun. Wurie’s motion to suppress the evidence obtained from the phone search was denied, and he was convicted.
Issue
The central issue before the Supreme Court was whether the police may, without a warrant, search digital information on a cell phone seized from an individual during an arrest.
Holding
The Court held that officers must generally secure a warrant before conducting such a search, establishing that the search incident to arrest doctrine does not apply to cell phones due to the substantial privacy concerns involved.
