Thornton v. United States
541 U.S. 615 (2004)
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Rule of Law:
The Fourth Amendment permits a police officer to conduct a search of a vehicle's passenger compartment incident to the lawful custodial arrest of a 'recent occupant,' even if the officer did not make contact with the person until after they had already exited the vehicle.
Facts:
- Officer Deion Nichols, driving an unmarked car, observed Marcus Thornton slow his vehicle to avoid driving alongside him.
- Nichols ran a check on Thornton's license plates and discovered they were issued to a 1982 Chevrolet, not the Lincoln Town Car Thornton was driving.
- Before Nichols could initiate a traffic stop, Thornton drove into a parking lot, parked his car, and exited the vehicle.
- Nichols parked behind Thornton's car, approached Thornton on foot, and asked for his driver's license, noting the license plate mismatch.
- Thornton appeared nervous, so Nichols asked for and received consent to conduct a pat-down search.
- During the pat-down, Thornton admitted to possessing drugs and pulled two bags of marijuana and crack cocaine from his pocket.
- Nichols arrested Thornton, handcuffed him, and secured him in the back of the patrol car.
- Following the arrest, Nichols searched Thornton's vehicle and discovered a 9-millimeter handgun under the driver's seat.
Procedural Posture:
- Marcus Thornton was charged in the U.S. District Court with possession with intent to distribute cocaine base and two firearms offenses.
- Thornton filed a motion to suppress the firearm found in his car, arguing it was the result of an unconstitutional search.
- The District Court, a court of first instance, denied the motion to suppress.
- Following a trial, a jury convicted Thornton on all three counts.
- Thornton (appellant) appealed the denial of his suppression motion to the United States Court of Appeals for the Fourth Circuit.
- The Court of Appeals, an intermediate appellate court, affirmed the District Court's decision, holding the search was reasonable under New York v. Belton.
- The U.S. Supreme Court granted Thornton's petition for a writ of certiorari to resolve the question.
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Issue:
Does the Fourth Amendment allow police to search the passenger compartment of a vehicle as a search incident to a lawful custodial arrest when the police first make contact with the person after they have already left the vehicle?
Opinions:
Majority - Chief Justice Rehnquist
Yes. So long as an arrestee is a 'recent occupant' of a vehicle, officers may search that vehicle incident to the arrest. The rule established in New York v. Belton, allowing a search of a vehicle's passenger compartment incident to an occupant's arrest, is not limited to situations where the officer initiates contact while the person is still inside the vehicle. The underlying rationales of Belton—officer safety and the need to preserve evidence—are equally present whether the arrestee is inside the car or has just exited it. A 'contact initiation' rule would be unworkable and subjective, undermining the clear, bright-line rule Belton sought to create. The danger to an officer flows from the fact of the custodial arrest and the arrestee's proximity to the vehicle, not the precise moment of initial contact.
Concurring - Justice O’Connor
Yes. While this decision is a logical extension of New York v. Belton, the state of the law in this area is unsatisfactory. Belton's foundational reasoning is shaky, and lower courts have increasingly treated the vehicle search as a police entitlement rather than a justified exception. Justice Scalia's proposed alternative rationale appears to be on firmer ground, but it would be improper to adopt it in this case because the parties have not had the opportunity to argue its merits.
Concurring - Justice Scalia
No, under the Court's reasoning, but yes as to the ultimate judgment. Applying the Chimel/Belton rationales of officer safety and evidence preservation to a suspect who is handcuffed and secured in the back of a squad car 'stretches it beyond its breaking point.' The risk of such an arrestee accessing the vehicle is 'remote in the extreme.' However, the search is justifiable on a different ground: that the search is permissible when it is reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle. Because Thornton was arrested for a drug offense, it was reasonable for the officer to believe that further contraband or drug-related evidence might be in the car from which he had just alighted.
Dissenting - Justice Stevens
No. The bright-line rule from Belton was created for the narrow and common circumstance of arresting an occupant of a vehicle, not for a pedestrian who was recently in a car. For individuals accosted outside their vehicle, the standard rule of Chimel v. California—limiting the search to the arrestee's immediate grabbing area—provides all necessary guidance. Extending Belton blurs its clear lines, fails to provide guidance on how 'recent' or 'close' is sufficient, and unjustifiably expands police search authority without the safety concerns that animated the original Belton decision.
Analysis:
This decision significantly broadened the practical application of the 'search incident to arrest' doctrine for vehicles by defining 'occupant' to include 'recent occupants.' It established that the timing of police contact is irrelevant, solidifying Belton as a bright-line rule based on the arrestee's status rather than a fact-specific inquiry into actual danger. However, the strong concurrences, particularly Justice Scalia's alternative evidence-gathering rationale, revealed deep fissures in the Court's support for Belton's original justification. This internal critique signaled that the doctrine was unstable and foreshadowed its eventual modification in Arizona v. Gant (2009), which adopted a version of Justice Scalia's reasoning.
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