United States v. Robinson
414 U.S. 218 (1973)
Author: DK

Facts: An officer spotted the respondent driving the car and officer had probable cause that respondent was driving the car after the revocation of his license.  Officer stopped the respondent and lawfully arrested him.  Officer patted down the person of the respondent and felt a cigarette packet and he further searched the packet and found heroin capsules.

Procedure: The Court of Appeals reversed the conviction of the respondent.

Issue:  Was the search of respondent constitutional?

Holding: Yes

Rationale:  According to the Court, it is well settled that a search incident to a lawful arrest is a traditional exception to the warrant requirement of the 4^th Amendment.  In Chimel v. California, the Court held that 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.  Furthermore, the justification or reason for the authority to search incident to a lawful arrest rests quite as much on the need to disarm the suspect in order to take him into custody as it does on the need to preserve evidence on his person for later use at trial.  Also, a custodial arrest of a suspect based on probable cause is a reasonable intrusion under the 4^th Amendment that intrusion being lawful, a search incident to arrest requires no additional justification.  Based on these reasons, the Court held that a search of the arrestee incident to a lawful arrest is not only a valid exception to the warrant rule but it is also reasonable under the 4^th Amendment.