Sunday, May 17, 2009

New York v. Belton, 453 U.S. 454 (1981)

Facts

A vehicle was stopped for speeding and the officer smelled burnt marijuana and saw an envelope he associated with marijuana.  The officer directed the men to get out of the car and placed them under arrest.  He patted them down, split them up, then searched the car finding Belton’s jacket, which contained cocaine.

Procedural History

Belton moved to suppress the cocaine the court denied the motion.  The New York Court of Appeals reversed, finding that the search of the jacket was not incident to the arrest.

Issue(s)

Did the New York Court of Appeals err in finding that the officer’s search of the pockets of the jacket was not a search incident to the arrest?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that 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.  It follows from this conclusion that the police may also examine the contents of any containers found within the passenger compartment.  In this case, the jacket was located within the passenger compartment of the car in which respondent had been a passenger just before he was arrested.  The jacket was thus within the area which we have concluded was within the arrestee’s immediate control.

Judgment/Outcome

The court reversed the judgment of the New York Court of Appeals.

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