Arizona v. Gant
Citation: 556 U.S. 332 (2009)
Facts
Rodney Gant was arrested for driving on a suspended license. After he was handcuffed and secured in a patrol car, officers searched his vehicle and found cocaine and a gun. The search was conducted without a warrant. The government relied on New York v. Belton (1981), which had been read by many lower courts to authorize a vehicle search incident to any arrest of a recent occupant.
Issue
Whether Belton permits a warrantless search of a vehicle incident to arrest when the arrestee is secured and cannot access the vehicle’s interior.
Holding
The Supreme Court held that police may search a vehicle incident to arrest only when (1) the arrestee is unsecured and within reaching distance of the passenger compartment, or (2) it is reasonable to believe the vehicle contains evidence of the offense of arrest. Because Gant was handcuffed and in the patrol car, neither condition was met.
Rule
A search incident to arrest of a vehicle is valid only if the arrestee is within reaching distance of the vehicle at the time of the search, or if police have reason to believe the vehicle contains evidence related to the arrest offense.
Significance
Gant significantly limited Belton’s broad rule and reaffirmed the nexus between the search-incident exception and its original rationales (officer safety and evidence preservation). It is a central vehicle search case and illustrates how the Court periodically reins in exceptions that have expanded beyond their justifications.