Thornton v. United States
Citation and Court
541 U.S. 615 (2004) — Supreme Court of the United States
Facts
Thornton was a “recent occupant” of a vehicle who parked and exited before the officer made contact with him. The officer then stopped Thornton, arrested him, and searched the passenger compartment of the car incident to arrest, finding drugs and a gun. Thornton argued New York v. Belton did not apply because he was not an occupant at the time of the stop.
Issue
Whether the Belton rule permitting search of a vehicle incident to arrest extends to a recent occupant who is contacted after exiting the vehicle.
Holding
Yes; the Belton rule applies to recent occupants who exit a vehicle shortly before police contact, allowing officers to search the passenger compartment incident to a lawful arrest.
Rule / Doctrine
The Belton search-incident-to-arrest exception for vehicle searches is not limited to suspects contacted while still inside the car. If the person was a recent occupant — that is, was in the vehicle just before the encounter — the search of the passenger compartment is still permissible as a contemporaneous search incident to arrest. (This rule was substantially narrowed by Arizona v. Gant (2009).)
Significance
Extended the Belton bright-line rule to recent occupants, but the practical importance was diminished by Arizona v. Gant, which held that Belton only permits a vehicle search when the arrestee is within reaching distance or when evidence of the offense of arrest might be found.