New York v. Belton, 453 U.S. 454 (1981)

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

• Lunney, Leslie A., The (Inevitably Arbitrary) Placement of Bright Lines: Belton and Its Progeny, Tulane Law Review 79 (2004): 365.
• Mokovitz, Myron, A Rule in Search of a Reason: An Empirical Reexamination of Chimel and Belton, Wisconsin Law Review 2002 (2002): 657.
• Shapiro, Eugene L., New York v. Belton and State Constitutional Doctrine, West Virginia Law Review 150 (2002): 131. Terry v. Ohio, 392 U.S. 1 (1968). United States v. Robinson, 414 U.S. 218 (1973).
• Cases and Statutes Cited
• Chimel v. California, 395 U.S. 752 (1969)

See also Arrest; Arrest without a Warrant; Automobile Searches; Chimel v. California, 395 U.S. 752 (1969); Exclusionary Rule; Search (General Definition); Seizures; Terry v. Ohio, 392 U.S. 1 (1968)