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Vale v. Louisiana
Supreme Court of United States (1970)
Petitioner/Defendant: Vale; the officers got arrest warrant for the defendant. Then they went to defendant's house where they saw the defendant making a drug deal. The officers arrested the defendant outside his house and then the officers went inside the house and in the back room, they found drugs. The defendant was convicted and now he appeals and argues that the evidence obtained in the house was result of an unlawful search. The Supreme Court of Lousiana affirmed the conviction by ruling that the search of the house was incident to a lawful arrest.
Issue: Was the search of the back room of the house incident to a lawful arrest?
Holding: No
Legal Reasoning: The court ruled that a search is incident to a lawful arrest "only if it is substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest." The court ruled that since the defendant was arrested outside his house, the back room of the house was not within the immediate vicinity of the arrest and also since the officers did not have exigent circumstances, or the consent of the defendant, they had no right to search the house. The conviction was reversed.