An officer is permitted to conduct a vehicle search when an arrestee is within reaching distance of the vehicle or it is reasonable to believe the vehicle contains evidence of the offense of arrest. Other established exceptions to the warrant requirement authorize a vehicle search when safety or evidentiary concerns demand. For instance, an officer is permitted to search a vehicle's passenger compartment when he has reasonable suspicion that an individual, whether or not the arrestee, is "dangerous" and might access the vehicle to gain immediate control of weapons. If there is probable cause to believe a vehicle contains evidence of criminal activity, a search of any area of the vehicle in which the evidence might be found is authorized. Searches for evidence relevant to offenses other than the offense of arrest are authorized, and the scope of the search authorized is broader. Finally, there may be still other circumstances in which safety or evidentiary interests would justify a search. These exceptions together ensure that officers may search a vehicle when genuine safety or evidentiary concerns encountered during the arrest of a vehicle's recent occupant justify a search.
After respondent was arrested for driving with a suspended license, handcuffed, and locked in the back of a patrol car, police officers searched his car and discovered cocaine in the pocket of a jacket on the backseat. The trial court denied respondent's motion to suppress evidence seized from his car. The case was appealed to Supreme Court of the United States. The Court determined that the search-incident-to-arrest exception to the Fourth Amendment warrant requirement did not justify the search.
Did the search violate the Fourth Amendment right of the defendant against unreasonable searches and seizures?
According to the Supreme Court, the vehicle of the respondent may be searched after the arrest for a suspended license only if the court believes that the arrestee may access the vehicle at the time of arrest or the latter contains evidence of the crime he was being arrested for.