Chimel v. California
Citation: 395 U.S. 752 (1969)
Facts
Police arrested Chimel in his home and, without a warrant, searched his entire three-bedroom house. The search turned up coins used to convict him of burglary. The state argued the full-home search was incident to the lawful arrest.
Issue
What is the permissible scope of a warrantless search incident to a lawful arrest?
Holding
A search incident to arrest is limited to the arrestee’s person and the area within the arrestee’s immediate control — the area from which the arrestee could reach to obtain a weapon or destroy evidence. A warrantless search of the entire house goes far beyond what is justified by the rationale for the search-incident-to-arrest exception.
Rule
Search incident to arrest — Chimel rule: A warrantless search incident to lawful arrest is constitutionally permitted as to: (1) the arrestee’s person, and (2) the area within the arrestee’s immediate control (lunge area / wingspan). The search may not extend beyond these limits without a warrant.
Justification: (1) officer safety (prevent access to weapons), (2) prevent destruction of evidence.
Significance
- Definitive case establishing the scope of the search-incident-to-arrest exception
- Later qualified by Arizona v. Gant: for vehicle searches incident to arrest, officers may search a vehicle only if the arrestee is unsecured and within reaching distance of the passenger compartment, or if it is reasonable to believe the vehicle contains evidence of the arrest offense
- Riley v. California: cell phones may not be searched incident to arrest without a warrant
- Maryland v. Buie: officers may conduct a protective sweep of adjacent areas if they have a reasonable belief that dangerous persons may be present