Summary of NEW YORK v. BELTON
453 U.S. 454, 101 S.Ct. 2860, 69 L.Ed.2d 768 (1981).
CAUSE OF ACTION: The defendant was arrested and indicted for possession of a controlled substance. This occurred as the result of a search by a New York State Trooper during a traffic stop. In trial court the defendant moved to have the seized cocaine found in his jacket pocket suppressed. The motion was denied. He pled guilty to a lesser charge but preserved his claim that the cocaine had been seized in violation of his Fourth and Fourteenth Amendment rights.The Appellate division of the New York Supreme Court upheld the constitutionality of the search and seizure. The New York Court of Appeals reversed, holding that there was no longer any danger that the arrestee or his confederates no longer had access to the jacket, thereby invalidating the search.
ISSUE: The question before the court in this case deals with the custodial arrest of an individual as a result of a traffic stop, and incidental to the arrest his legal standing in regard to a subsequent search of the vehicle and the contents inside the car.
FACTS: The trooper stopped a speeding vehicle with four men in the vehicle.The trooper smelled burnt marijuana and saw an envelope marked ‘Supergold’ in the vehicle. He associated the envelope with marijuana. The trooper told the men to get out of the car and placed them under arrest for possession of marijuana.The four men were separated out of physical touching area of each other.The trooper opened the envelope and discovered marijuana. The arrestees were advised of their Miranda rights. The trooper searched each individual and then the passenger area of the car. A jacket belonging to Belton was found on the back seat. In the pocket the trooper found cocaine.
HOLDING: The court held that when a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile.
RATIONALE: The court states that the first principle of Fourth Amendmentis that police may not conduct a search unless they first convince a neutral magistrate that there is probable cause to do so. They also recognized that the exigencies of the situation make exemptions from the warrant requirements imperative. The court held in Chimel v. California that a lawful arrest custodial arrest creates a situation, which justifies the contemporaneous search without a warrant of the person, arrested and the area immediately surrounding. The court states that the Chimel case established