395 U.S. 752 (1969).
Summary: In Chimel, the United States Supreme Court attempted to delineate the proper bounds of a warrantless search incident to a lawful arrest.
The case involved a lawful arrest of the defendant who was arrested in his home for the burglary of a coin shop. For approximately an hour after the arrest, the police officers conducted a detailed search of defendant’s entire house, finding several items of evidence that were later used against him. The police were armed with a warrant for the defendant’s arrest, but had no warrant or defendant’s consent to search the house.
The Court ruled that the search and seizures were unlawful, because the search exceeded the permissible scope of a search incident to defendant’s arrest. The Court found that the Fourth Amendment set forth a preference for prior judicial approval of searches, and any exceptions to the warrant requirement are limited in scope by the justifications allowing the initiation of the search. The Court stated:
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. Otherwise, the officer’s safety might well be endangered, and the arrest itself frustrated. In addition, 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 into which an arrestee might reach in order to grab a weapon or an evidentiary item must, of course, be governed by a like rule. A gun on a table or in a drawer in front of one who is arrested can be as dangerous to the arresting officer as one concealed in clothing of the person arrested. There is ample justification, therefore, for a search of the arrestee’s person and the area ‘within his immediate control’ – construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence.”
Id. at 762-63.
However, the Court explained, the exception for search incident to a lawful arrest has limits:
There is no comparable justification . . . for routinely searching any room other than that in which an arrest occurs—or, for that matter, for searching through all the desk drawers or other closed or concealed areas in that room itself. Such searches, in the absence of well-recognized exceptions, may be made only under the authority of a search warrant. The ‘adherence to judicial processes’ mandated by the Fourth Amendment requires no less.
Id. at 763.
The Court held that the warrantless search at issue violated the Fourth Amendment because it extended beyond defendant’s person and area from which he might have obtained either weapon or something that could have been used as evidence against him.