New York v. Belton
Citation and Court
453 U.S. 454 (1981) — Supreme Court of the United States
Facts
A state trooper stopped a car for speeding and smelled marijuana. After arresting all four occupants and securing them outside the vehicle, he searched the passenger compartment and found cocaine in a jacket on the back seat. Belton moved to suppress, arguing the search incident to arrest could not extend to the entire compartment.
Issue
Whether an officer may search the passenger compartment of an automobile as incident to a lawful arrest of its occupant.
Holding
Yes; when a police officer lawfully arrests an occupant of an automobile, the officer may search the passenger compartment of that automobile as a contemporaneous incident of that arrest.
Rule / Doctrine
As a bright-line rule incident to the authority to search the person of an arrestee, officers may search the entire passenger compartment of a vehicle — including any containers, open or closed — without a warrant when the occupant has been lawfully arrested. The search need not be limited to the area within the arrestee’s immediate reach.
Significance
Provided a clear, administrable rule for vehicle searches incident to arrest, but was substantially narrowed by Arizona v. Gant (2009), which held that Belton permits a vehicle search only when the arrestee is unsecured and within reaching distance of the passenger compartment, or when it is reasonable to believe the vehicle contains evidence of the offense of arrest.