Thornton v. United States, 124 S. Ct. 2127 (2004)

Facts

Nichols was driving an unmarked police car and noticed that Thornton seemed to avoid driving next to him.  Nichols pulled off onto a side street and ran the tags on Nichols car.  He discovered that the tags were for a two-door Chevrolet, not Thornton’s Lincoln Town Car.  Thornton had pulled into a parking lot and Nichols stopped Thornton as he was walking from the car.  After searching Thornton, with his consent, and discovering narcotics, Thornton was placed under arrest.  Nichols then search Thornton’s car, finding a 9mm handgun under the driver’s seat.

Procedural History

Thornton sought to suppress the handgun but the District Court denied the motion.  Thornton was convicted on all three counts.

Issue(s)

Did the lower courts err in admitting the evidence of the handgun when Thornton had been arrested and placed in the patrol car before the search occurred?

Holding(s)

No.

Reasoning/Analysis

The Court found that the arrest of a suspect who is next to a vehicle presents no identical concerns regarding officer safety and the destruction of evidence as the arrest of one who is inside the vehicle.  It is unlikely that Thornton could have reached for the gun after he was outside his automobile, but the need for a clear rule justifies the sort of generalization which Belton enunciated.  So long as an arrestee is the sort of recent occupant of a vehicle such as petitioner was here, officers may search that vehicle incident to the arrest.

Judgment/Outcome

The Court affirmed the judgment of the Court of Appeals.