453 U.S. 454 (1981).
One-Sentence Takeaway: When an officer has made a lawful custodial arrest of the occupants of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile and may also examine the contents of any containers found within the passenger compartment.
Summary: A state police trooper stopped a vehicle for speeding. None of the occupants owned the car or knew the registered owner. While examining the driver’s license and registration of the car, the officer smelled burnt marijuana and saw an envelope marked “Supergold,” which he suspected contained marijuana, on the floor of the car. The officer directed the four occupants to exit the car, placed the occupants under arrest for possession of marijuana, patted each down, and instructed them to stand in separate areas of the highway. The officer found marijuana in the envelope. He then searched the passenger compartment of the car and found cocaine in one of the pockets of a jacket.
The issue presented to the Supreme Court was: “When the occupant of an automobile is subjected to a lawful custodial arrest, does the constitutionally permissible scope of a search incident to his arrest include the passenger compartment of the automobile in which he was riding”? Id. at 455. The Court answered this question by holding that “when a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident to arrest, search the passenger compartment of that automobile as well as the contents of any containers found in that compartment”. Id. at 460-61 & n.4.
The Court ruled that the search of the jacket was a search incident to a lawful custodial arrest for possession of marijuana. The Court reasoned that the four occupants were inside the car at the time of arrest. The jacket was located inside the passenger compartment of the car in which Belton had been a passenger just before he was arrested.
The jacket was, thus, within the area which was “within the arrestee’s immediate control” within the meaning of the Chimel v. California holding regarding the proper scope of a warrantless search incident to a lawful arrest. The court reasoned 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 in order to grab a weapon or evidentiary ite[m].”’ Id. at 460.
In reaching its decision, the Court wrote that its holding in no way altered “the fundamental principles established in the Chimel case regarding the basic scope of searches incident to lawful custodial arrest”. Rather, the Belton decision was merely an interpretation of Chimel’s principles in the “particular and problematic context” of automobiles. Id. at 460 n.3.
Dissent: Four Justices disagreed with the Court’s holding, warning that it portended “an extreme extension of Chimel,” id. at 472 (White, J., dissenting), because there was “no chance” that Belton or any of the other arrestees in the case – all of whom had been removed from their car and were under police control at the time of the search – could have grabbed anything inside the car, id. at 468 (Brennan, J., dissenting).