The Law School Authority

Arizona v. Gant Case Brief

Summary of  Arizona v. Gant

Relevant Facts: Rodney Gant was arrested by Arizona state police due to driving a vehicle with a suspended license. Upon handcuffing Gant and placing him in the back of the squad car, the arresting officers searched Gant’s vehicle and found a handgun and a plastic bag of cocaine. During the trial phase of his case, Gant petitioned the judge to suppress the handgun and cocaine evidence found in his car on the grounds that the police lacked a warrant to search his vehicle, in violation of the Fourth Amendment’s prohibition of unreasonable searches and seizures. The judge denied Gant’s motion, ruling that the evidence was obtained during a legitimate traffic stop that was the result of a legitimate arrest based upon his outstanding warrant.  Gant was convicted of cocaine possession (two counts).  Gant appealed his conviction to the Arizona Court of Appeals which reversed the trial court decision on the grounds that the search was in fact unconstitutional.  The Arizona Supreme Court agreed. The Arizona Supreme Court reasoned that while there can be exceptions to the need for a warrant, those exceptions are predicated on the condition that the officer has an overwhelming safety concern or concern for the preservation of evidence, both of which had not either been present or at least affirmed in the Gant case.  The Court further reasoned that since Gant left his vehicle on his own volition, there was no pressing concern for evidence preservation or officer safety.  The evidence thus needed to have been collected only after a warrant was issued.   The Arizona Attorney General, Terry Goddard, argued when petitioning to the U.S. Supreme Court that the Arizona Supreme Court’s ruling did not comport with federal and state court precedent on evidence gathering at the scene of a traffic stop.

Issue:  The legal question presented was whether searches and seizures performed by police officers after handcuffing a defendant and securing the crime scene violate an individual’s Fourth Amendment protection to be free from unreasonable searches and seizures.

Holding: The Supreme Court held that yes, at least with regards to the case before the Court, there was a violation of Gant’s Fourth Amendment rights.

Majority Opinion Reasoning:  The Court ruled that assuming that the scene and the suspect have both been secured, a warrant is needed to search the contents of a vehicle.  The Court found that by nature, warrantless searches are unreasonable except for a few very particular reasons, namely issues of officer safety.  However, if there are no exigent safety circumstances, officers are duty bound to use the proper constitutional and police procedure by obtaining a warrant. Furthermore, since Gant, as far as the officers knew, was merely driving on a suspended license as opposed to a more serious offense, the nature of the crime did not rise to the level of warranting a warrantless search.

Dissenting Opinion: Alito, Roberts, Kennedy and Breyer dissented, arguing that the Court erred by overruling its opinion and the precedent set in the New York v. Belton case in which the Court reasoned that “when a policeman has made a lawful arrest… he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile.”  In short, the dissenters argued that any officer has a right to search the contents of a vehicle when the driver has been pulled over for a traffic violation which had been the precise situation in Gant’s case.

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