New York v. Belton

New York v. Belton

453 U.S. 454 (1981) [p. 163]

ISSUE: May a police officer search the passenger compartment of a vehicle and containers inside it without a warrant incident to a valid arrest of its occupants?
HOLDING: Yes, when a police officer has made a lawful custodial arrest of the occupant of a vehicle, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that vehicle.
FACTS:
  • Officer saw D driving the vehicle at a high rate of speed, so he gave chase and pulled the vehicle over
  • Officer smelled a strong odor of marijuana and noticed an envelope marked "Supergold" on the floor of the car
  • Officer arrested all of the occupants and then searched the passenger compartment and jackets in the backseat and found cocaine in one of the pockets
RULES:
  • Robinson: In the case of a lawful custodial arrest, a full search of the person is not only an exception to the warrant requirement of the 4th Amdt., but is also a "reasonable" search under that Amdt.
REASONING:
  • Can search passenger compartment: When a police officer has made a lawful custodial arrest of the occupant of a vehicle, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that vehicle
    • Need for bright line rules for police officers in the field
    • Articles in passenger compartment and its containers are necessarily ones that are within the immediate control of the occupants
    • May search closed containers in the interior
    • May NOT search the trunk
  • Valid search here: Since the arrest was valid, the search of the passenger compartment and the jackets was also valid, even without a warrant

DISSENT:

  • Chimel exception to warrant requirement no longer applies when the occupants are safely taken into custody
  • Fiction that the interior of a car is always within the immediate control of the occupants
  • Neither D nor the other occupants could have reached the jackets after arrest
  • Cannot justify a disregard of the 4th Amdt. by the need for more efficient law enforcement
  • No indication by majority of how long after arrest the police can search the vehicle
  • What about areas under floorboards, inside the paneling, etc.? -- no bright line answers to these questions
DISSENT: Need to exercise more caution under the 4th Amdt. then just allowing searches of closed containers without any suspicion whatsoever
COMMENTS:
  • It is important to note that after Arizona v. Gant, Belton is limited to its facts, i.e., when an arrestee is unsecured and within reaching distance of the vehicle at the time of arrest.
  • Practitioners, cite Belton with great care in order to avoid using bad case law. Please see the notes after my Gant brief.

 

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