Brief Fact Summary. A police officer arrested four people in a speeding car. He examined passenger compartment, and found a jacket containing incriminating evidence.
Synopsis of Rule of Law. “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” and that “the police may also examine the contents of any containers found within the . . . compartment.”
Issue. Whether “the constitutionally permissible scope of a search incident to his arrest include the passenger compartment of the automobile in which he was riding.”
Held. Yes. The court set out to firmly define the parameters of a search incident to arrest, established under previous law as “the area within the immediate control of the arrestee.” A reading of case law “suggests the generalization that articles inside the relatively narrow compass of the passenger compartment of an automobile are in fact generally, even if not inevitably, within ‘the area into which an arrestee might reach . . . a weapon” or evidence. Any containers within the passenger compartment could be searched for that same reason.
Because of this disposition of the case, there is no need here to consider whether the search and seizure were permissible under the so-called automobile exception.View Full Point of Law