New York v. Belton:   
United States Supreme Court, 1981. 

Statement of the Case:

      Belton, the ?, was arrested and indicted for possession of a controlled substance when the police searched the car he was riding in after he was arrested, opened his coat pocket, and found cocaine.

Procedure:

      Trial court convicted ?.

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 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.

Issue:

      Whether a police officer can search the inside of a car after arresting the people riding in it, and taking them out of immediate proximity of the car.

Procedural Result:

      Judgment was reversed.

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.

Reasoning:

• The court states that the first principle of Fourth Amendment is that police may not conduct a search unless they first convince a neutral magistrate that there is probable cause to do so.
• Chimel held that a lawful arrest custodial arrest creates a situation, which justifies the contemporaneous search without a warrant of the person who was arrested, and the area immediately surrounding.
• This court claims not to change Chimel at all, but they hold that a jacket inside the passenger compartment of a car, where the ? had been a passenger just before his arrest, was within his “immediate control,” within the meaning of the Chimel case.

Dissent:

• This “bright-line” rule ignores the policy considerations carefully crafted from Chimel.
• Chimel was meant for the safety of the arresting officer, and preserving easily concealed or destroyed evidence.
• The court, instead, adopts a fiction that the inside of a car is ALWAYS within the immediate control of an arrestee who had just been inside of it.
• Court uses the excuse of creating a bright line rule to aid officers for a reason to change Chimel.

Additional Points: 

Thornton v. United States (US, 2004):

• Belton governs even when an officer does not make contact with the person until he has stepped from his vehicle.
• Thornton was arrested with crack and marijuana.  He met the officer outside his car, and after being handcuffed and placed in the car, a search of the car was deemed reasonable.
• Dissent – Scalia:  Belton allows for purely-exploratory searches of cars, without the considering the Chimel issues.  If the court is going to do this, it should admit it is allowing it.

Washington v. Chrisman (US, 1982):

• Held it is not unreasonable for an officer to monitor the movements of an arrested person, as his judgment dictates, after an arrest.
• Arrestee wanted to enter his dorm room, but reneged when officer stated he would have to accompany him.