Chimel v. California

Chimel v. California

United States Supreme Court
395 U.S. 752 (1969)

ISSUE: Did a search of D's entire house including closed desk drawers following his valid arrest amount to an unreasonable search under the 4th Amdt.?
HOLDING: Yes, the search was unreasonable because it far exceeded D's person and immediate area.
FACTS:
  • Police served an arrest warrant on D in his home stemming from the burglary of a coin shop
  • When D came home, he objected to the search, but an officer told him it was a search incident to lawful arrest
  • Officers looked through the entire 3-bedroom house with D's wife and made her open drawers and shift contents
  • Police seized many coins, medals, tokens, and other objects
PROCEDURAL HISTORY:
  • Lower courts held the arrest and search lawful
RULES:
  • Rabinowitz: A warrantless search "incident to a lawful arrest" may generally extend to the area that is considered to be in the "possession" or under the "control" of the person arrested
REASONING:
  • Rabinowitz too broad: Warrant requirement is not to be lightly dispensed with given the history of abuses suffered by the colonists that gave rise to the 4th Amdt.'s proscription on unreasonable searches and seizures
  • Reasonable search incident to arrest: When an arrest is made, it is reasonable for the arresting officer to search the person arrested for weapons and evidence and the area "within his immediate control," i.e., the area into which an arrestee might reach in order to grab a weapon or evidentiary items
    • No justification for searching any other rooms besides the one the arrest occurs in or desk drawers
  • Present search unreasonable: Search of D's entire house far exceeded the reasonable search allowed incident to arrest

 

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