New York v. Belton

Supreme Court of United States
453 U.S. 454 (1981)

ELI5:

Rule of Law:

When a police officer has made a lawful custodial arrest of a recent occupant of an automobile, the officer may, as a contemporaneous incident of that arrest, search the passenger compartment of that vehicle and any containers found within it.

Facts:

New York State Trooper Douglas Nicot stopped a speeding car occupied by four men, including Roger Belton.
Upon approaching the car, Trooper Nicot smelled burnt marihuana and saw an envelope on the floor marked 'Supergold,' which he associated with marihuana.
Nicot ordered the four men out of the car, placed them under arrest for unlawful possession of marihuana, and patted them down.
He separated the four men on the side of the Thruway so they were not in physical contact with each other or the vehicle.
After securing the men, Nicot searched the passenger compartment of the car.
On the back seat, Nicot found a black leather jacket belonging to Belton, unzipped one of its pockets, and discovered cocaine.

Procedural Posture:

Roger Belton was indicted for criminal possession of a controlled substance in a New York trial court.
Belton filed a motion to suppress the cocaine, arguing it was seized in violation of the Fourth Amendment, which the trial court denied.
Belton pleaded guilty to a lesser included offense but preserved his right to appeal the suppression ruling.
The Appellate Division of the New York Supreme Court, an intermediate appellate court, affirmed the trial court's decision, finding the search was justified.
Belton appealed to the New York Court of Appeals, the state's highest court, which reversed the lower courts' decisions.
The New York Court of Appeals held that a warrantless search of a zippered pocket of an inaccessible jacket was not a valid search incident to a lawful arrest.
The State of New York (petitioner) sought and was granted a writ of certiorari by the U.S. Supreme Court.

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Issue:

Does the Fourth Amendment permit a police officer, as a contemporaneous incident of a lawful custodial arrest of an automobile's occupant, to search the passenger compartment of that vehicle and any containers found within it, even after the arrestee has been removed from the vehicle?

Opinions:

Majority - Justice Stewart

Yes. 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 and any containers found within it. This creates a straightforward, workable rule for police officers, who need clear guidance in the field. The Court's previous ruling in Chimel v. California allowed for a search of the area within an arrestee's 'immediate control,' but courts have struggled to apply this standard to vehicle searches. To provide a clear standard, the entire passenger compartment of a vehicle is deemed to be within the 'immediate control' of a recent occupant, justifying a search for officer safety and to prevent the destruction of evidence.

Dissenting - Justice Brennan

No. A warrantless search of an inaccessible jacket pocket cannot be upheld as a search incident to arrest when there is no longer any danger that the arrestee could gain access to it. The majority's decision disregards the core principles of Chimel, which limits such searches to the area an arrestee can actually reach to grab a weapon or evidence. In this case, Belton and his companions were removed from the car, separated, and under police control, making it impossible for them to access the jacket. The Court's new 'bright-line' rule is a legal fiction that dangerously expands police power without the justification of exigency that underlies the search-incident-to-arrest exception.

Dissenting - Justice White

No. The majority's holding is an extreme and unwarranted extension of Chimel. It authorizes the search of containers like luggage and briefcases found inside a car's passenger compartment incident to an arrest without any probable cause to believe they contain contraband. This is a departure from precedent which has historically recognized a separate privacy interest in such containers.

Concurring - Justice Rehnquist

The opinion of the Court is joined because the Court is unwilling to overrule Mapp v. Ohio and does not need to consider the 'automobile exception' to decide the case.

Concurring - Justice Stevens

The judgment to reverse should be upheld for reasons stated in his dissenting opinion in the related case of Robbins v. California.

Analysis:

This case established the 'Belton rule,' a significant bright-line rule that expanded the scope of searches incident to the lawful arrest of a vehicle's occupants. It departed from a strict, fact-based application of the Chimel 'wingspan' test in the automobile context, prioritizing a clear, easily applicable standard for police over a case-by-case analysis of the arrestee's actual reach. This decision provided law enforcement with broad authority to search the entire passenger compartment and any containers within it following an arrest, a standard that would remain influential for decades until it was substantially narrowed by Arizona v. Gant in 2009. The case highlights the ongoing tension between creating workable rules for law enforcement and protecting individual privacy rights under the Fourth Amendment.

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