New York V. Belton - Opinion of The Court

Opinion of The Court

The Supreme Court noted that no straightforward rule has emerged from the litigated cases respecting the question ... of the proper scope of a search of the interior of an automobile incident to a custodial arrest of its occupants. The Court thus resolved to establish a definitive rule and held:

Our reading of the cases suggests the generalization that articles inside the relatively narrow compass of the passenger compartment of an automobile are in fact generally, even if not inevitably, within "the area into which an arrestee might reach in order to grab a weapon or evidentiary ite. Chimel, supra, at 763. In order to establish the workable rule this category of cases requires, we read Chimel's definition of the limits of the area that may be searched in light of that generalization. Accordingly, we hold that when a 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 that automobile.

It follows from this conclusion that 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. United States v. Robinson, supra; Draper v. United States, 358 U.S. 307 . 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. Thus, while the Court in Chimel held that the police could not search all the drawers in an arrestee's house simply because the police had arrested him at home, the Court noted that drawers within an arrestee's reach could be searched because of the danger their contents might pose to the police. Chimel v. California, supra, at 763.

The Court distinguished the Chadwick and Sanders situations as not involving an arguably valid search incident to a lawful custodial arrest.

Thus, under Belton, the entire passenger compartment of an automobile is subject to search under the search incident doctrine even if the arrestee is out of the car.

A nexus is required between the vehicle and the person arrested with or in the vehicle prior to the arrest.