Law School Case Brief
New York v. Belton - 453 U.S. 454, 101 S. Ct. 2860 (1981)
When a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile. The police may also examine the contents of any containers found within the passenger compartment, for if the passenger compartment is within reach of the arrestee, so also will containers in it be within his reach. Such a container may, of course, be searched whether it is open or closed, since the justification for the search is not that the arrestee has no privacy interest in the container, but that the lawful custodial arrest justifies the infringement of any privacy interest the arrestee may have.
Defendant was a passenger in an automobile that sped by a police officer at a fast rate. Upon stopping the car, the officer smelled marijuana smoke and saw an envelope on the car's floor that was marked with a name for marijuana. The officer therefore required the occupants to get out of the vehicle and proceeded to search them. He opened the envelope and found that it contained marijuana. He also searched defendant's jacket in the vehicle and found cocaine. In defendant's subsequent drug prosecution, the trial court denied his motion to suppress the items seized in the search of the vehicle. However, the New York Court of Appeals reversed, holding that the search of the jacket was not incident to defendant's arrest. The United States Supreme Court granted certiorari to review the decision of the Court of Appeals.
Was there a lawful search of a car without a warrant after the occupants were separated from the vehicle and under arrest?
The Court reversed the judgment of the state court and held that items seized in the warrantless search of a passenger compartment of a vehicle, incident to a lawful custodial arrest, were lawfully seized during the exigencies of the situation and such seizure did not violate the safeguards of the Fourth and Fourteenth Amendments of the constitution. A policeman who has made a lawful custodial arrest of the occupant of an automobile may, as a contemporaneous incident of that arrest, search the passenger compartment of the automobile and may examine the contents of any containers found within the passenger compartment, the term "container" denoting any object capable of holding another object and including closed or opened glove compartments, consoles, or other receptacles, as well as luggage, boxes, bags, clothing, and the like, and (2) the search of the jacket was a search incident to a lawful custodial arrest and did not violate the Fourth and Fourteenth Amendments, it not being questioned that the jacket's owner was the subject of a lawful custodial arrest on a charge of possessing marijuana, the search following immediately upon that arrest, and the jacket being located inside the passenger compartment of the car in which the owner had been a passenger just before he was arrested.
Access the full text case
Not a Lexis+ subscriber? Try it out for free.
Be Sure You're Prepared for Class