Summary of Chimel v. California
395 U.S. 752, 89 S.Ct. 2034, 23 L.Ed.2d 685 (1969)
ISSUE: Whether the warrantless search of an arrestees entire house can be constitutionally justified as incident to the arrest itself?
FACTS: A warrant for the arrest of the petitioner was made for the burglary of a coin shop. The officers identified themselves and were allowed entrance to the house by the petitioner’s wife where they waited for the accused man to come home. Upon arrival of the petitioner, the arresting officers showed the arrest warrant to the accused and asked permission to “look around". The petitioner refused the request and the officers told the petitioner that a search could be conducted on “the basis of lawful arrest" and carried out the search. The officers searched the entire house including the attic, garage, and a small workshop, etc. and found various items which were admitted as evidence in court, over the defendants objection that they were admitted unconstitutionally.
DECISIONS OF THE LOWER COURTS: The judgment of the district court found the defendant guilty on two counts of burglary. All appellate courts in the state of California affirmed the judgment of the district court. A writ of certiorari was granted to the petitioner by the Supreme Court.
HOLDING: The judgment of the district court is reversed.
RATIONALE: The decision of the Supreme Court, delivered by Justice Stewart, was based on the decision of United States v. Rabinowitz and that the search was unreasonable under the 4th and 14th Ammendments. Until this point in time, a “warrantless search incident to a lawful arrest may general extend to the area that is considered to be in the possession or under the control of the person arrested." The Court held that a warrantless search was reasonable only of the defendant’s person i.e. whatever he/she has in pockets and etc. as well as anything that may be in reach such as a weapon in a nearby drawer. When an arrest is made, it is reasonable for the arresting officer to search the person arrested in order to remove any weapons that the latter might seek to use in order to resist arrest or effect his escape . . . it is entirely reasonable for the arresting officer to search for and seize any evidence on the arrestee’s person in order to prevent its concealment or destruction. And the area which an arrestee might reach in order to grab a weapon or evidentiary items must, of course, be governed by a like rule. The Court felt that there was “no comparable justification, for routinely searching rooms other than that in which an arrest occurs…" “Such searches, in the absence of well recognized exceptions, may be made only under the authority of a search warrant." The court held the opinion that the 4th Amendment, at no point, allowed a search to go beyond that of the area where the person is arrested “from which the person might obtain weapons or evidentiary items."
CONCURRING OPINIONS: Justice Harlan concurred with the opinion of the Court in that “as a result of Mapp v. Ohio, every change in the 4th Amendment law must now be obeyed by state officials facing widely different problems of local law enforcement". Justice Harlan also states “the warrant requirement plays an essential role in the protection of those fundamental liberties protect again state infringement by the 4th Amendment."
DISSENTING OPINIONS: Justice White and Justice Black join dissenting claiming that a search in a case such as this is justified for the fact that if the petitioner had been arrested at his place of work, a warrant would have been obtained to search his home at a later time. Also, if they had left the premises of the home where the arrest was made to obtain a warrant to search the content of the house, the spouse of the defendant, knowing that her husband had committed a crime, may have removed the evidence from its location where it may have never been found.
POLICY EFFECT: The outcome of Chimel v. California held that upon arrest, only a person’s body and immediate area is justified by a warrantless search. Searching beyond those points must be accompanied by a search warrant