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New York v. Belton

Supreme Court of the United States · 1981 · Criminal Procedure
Criminal ProcedureFourth Amendmentsearch incident to arrestautomobilepassenger compartmentFourth Amendmentsearch incident to arrestlawful custodial arrest

Facts

A New York state trooper stopped a speeding car occupied by four men, including Belton. After smelling burnt marihuana and seeing an envelope associated with marihuana on the car floor, the trooper ordered the men out, arrested them for unlawful possession of marihuana, and separated them along the roadside. He then searched the passenger compartment and found Belton's black leather jacket on the back seat; when he unzipped a pocket, he discovered cocaine. Belton sought suppression of the cocaine as the product of an unconstitutional search.

Issue

When a police officer lawfully makes a custodial arrest of the occupant of an automobile, may the officer, as a search incident to arrest, search the passenger compartment of the car and containers found there? Specifically, could the officer lawfully search Belton's jacket pocket located on the back seat?

Rule

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, whether open or closed, because those containers are treated as within the arrestee's immediate control for this purpose. This rule does not extend to the automobile's trunk.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, Officer Lena Ortiz lawfully made a custodial arrest of Devon Pike for driving with probable cause to believe he possessed illegal pills after stopping his car. Immediately after handcuffing Devon outside the car, she searched the front and back seating areas and found incriminating papers under the passenger seat.

Are the papers admissible as the product of a valid search incident to arrest?

Explanation. The majority adopted a workable rule: when police lawfully make a custodial arrest of an occupant of an automobile, they may, as a contemporaneous incident of that arrest, search the passenger compartment. The rule does not require case-by-case litigation over whether the arrestee could actually reach the area at that moment.