In NewYork v. Belton, the Supreme Court examined the permissible scope of a search incident to arrest, particularly in the context of a vehicle search. The Court had previously developed the search incident to arrest rule primarily to address officer safety concerns and to minimize the potential for destruction of evidence. Belton was a passenger in a vehicle stopped for speeding. The arresting officer suspected that the car was stolen and ordered all occupants out of the vehicle. He searched the passenger compartment, including a jacket belonging to Belton and discovered cocaine. The trial court found the search permissible under the Fourth Amendment and the Supreme Court affirmed. In a departure from Chimel v. California (1969), in which the Court had limited the permissible scope of a search incident to arrest to ‘‘the area within the immediate control of the arrestee,’’ the Belton Court emphasized the importance of establishing a ‘‘workable rule’’ that is readily applicable to police officers.
The Court determined that an officer may permissibly search the entire passenger compartment of a vehicle, including any closed containers within it, following the arrest of a recent occupant of the vehicle. The Court established this bright-line rule where vehicles are concerned, even though the arrestee may be detained outside the car at the time and may pose no danger of accessing a firearm or other contraband from within the vehicle. In a noteworthy dissent, Justices Brennan and Marshall criticized the majority for abandoning the careful case-by-case analysis of Chimel and its progeny in favor of an ‘‘arbitrary ‘bright-line’ approach.’’
STEPHANIE ROBERTS HARTUNG
References and Further Reading