SUPREME COURT OF THE UNITED STATES
Arizona v. Gant
No. 07–542.
Decided April 21, 2009
Rodney Gant was arrested for driving on a suspended license, handcuffed, and locked in patrol car before officers searched his car and found cocaine in a jacket pocket. The Arizona trial court denied his motion to suppress the evidence, and he was convicted of drug offenses. Reversing, the Arizona State Supreme Court distinguished New York
v. Belton, 453 U. S. 454—which held that police may search the passenger compartment of a vehicle and any containers therein as a contemporaneous incident of a recent occupant’s lawful arrest—on the ground that it concerned the scope of a search incident to arrest but did not answer the question whether officers may conduct such a search once the scene has been secured.
Because Chimel v. California, 395 U. S. 752, requires that a search incident to arrest be justified by either the interest in officer safety or the interest in preserving evidence and the circumstances of Gant’s arrest implicated neither of those interests, the State Supreme Court found the search unreasonable.
The United States Supreme Court held that the police may search the passenger compartment of a vehicle incident to a recent occupant’s arrest only if it is reasonable to believe that the arrestee might access the vehicle at the time of the search or that the vehicle contains evidence of the offense of arrest. Pp. 5–18.
The Court ruled that:
(a) Warrantless searches “are per se unreasonable,” “subject only to
a few specifically established and well-delineated exceptions.” Katz
v. United States, 389 U. S. 347, 357. The exception for a search inci-
dent to a lawful arrest applies only to “the area from within which
[an arrestee] might gain possession of a weapon or destructible evi-
dence.” Chimel, 395 U. S., at 763. This Court applied that exception
to the automobile context in Belton, the holding of which rested in
large part on the assumption that articles inside a vehicle’s passen-
ger compartment are “generally . . . within ‘the area into which an
arrestee might reach. ” 453 U. S., at 460. Pp. 5–8.
(b) The Court rejects a broad reading of Belton that would permit a
vehicle search incident to a recent occupant’s arrest even if there
were no possibility the arrestee could gain access to the vehicle at the
time of the search. The safety and evidentiary justifications underly-
ing Chimel’s exception authorize a vehicle search only when there is
a reasonable possibility of such access. Although it does not follow
from Chimel, circumstances unique to the automobile context also
justify a search incident to a lawful arrest when it is “reasonable to
believe evidence relevant to the crime of arrest might be found in the
vehicle.”
(c) The Court is not persuaded by the State’s argument that its ex-
pansive reading of Belton correctly balances law enforcement inter-
ests with an arrestee’s limited privacy interest in his vehicle. The
State seriously undervalues the privacy interests at stake, and it ex-
aggerates both the clarity provided by a broad reading of Belton and
its importance to law enforcement interests. A narrow reading of
Belton and Thornton, together with this Court’s other Fourth
Amendment decisions, e.g., Michigan v. Long, 463 U. S. 103, and
United States v. Ross, 456 U. S. 798, permit an officer to search a ve-
hicle when safety or evidentiary concerns demand.
(d) Stare decisis does not require adherence to a broad reading of
Belton. The experience of the 28 years since Belton has shown that
the generalization underpinning the broad reading of that decision is
unfounded, and blind adherence to its faulty assumption would au-
thorize myriad unconstitutional searches.
