Police officers went to Chimel’s home with an arrest warrant for his arrest for burglary of a coin shop. Although they had no search warrant, officers conducted a comprehensive search of the entire house, including drawers and other closed areas, over Chimel’s objection. The officers seized coins, medals, and other items later used against him at trial. Chimel was convicted, and California courts upheld the search as incident to a lawful arrest.
When police lawfully arrest a person in his home, may they, without a search warrant, search the entire house as a search incident to arrest?
A search incident to a lawful arrest is limited to the arrestee’s person and the area within his immediate control—meaning the area from within which he might gain possession of a weapon or destructible evidence. Absent another exception, the Fourth Amendment does not permit a warrantless search of rooms or closed areas beyond that immediate reach.
No. The warrantless search of Chimel’s entire home was unreasonable under the Fourth and Fourteenth Amendments because it exceeded the permissible scope of a search incident to arrest.
The Court explained that the justifications for a search incident to arrest are officer safety and preservation of evidence. Those interests justify searching the arrestee and the area within his immediate control, but they do not justify a broad exploratory search of the home. The Court rejected broader prior approaches that had allowed more extensive warrantless searches following arrest, emphasizing the central Fourth Amendment preference for warrants. Because officers had no search warrant and searched well beyond Chimel’s reach, the search was unconstitutional.
Yes. Justice White, joined by Justice Black, dissented, arguing the Court unnecessarily departed from prior precedent allowing broader searches incident to arrest and adopted an impractical rule. Justice Stewart also dissented separately.
Chimel is the leading case defining the modern scope of the search-incident-to-arrest exception in homes, sharply limiting such searches to the arrestee and the area within immediate control. It curtailed broader readings associated with United States v. Rabinowitz, 339 U.S. 56 (1950), and distinguished Preston v. United States, 376 U.S. 364 (1964). Its rule later shaped cases applying and refining the doctrine, including New York v. Belton, 453 U.S. 454 (1981), Arizona v. Gant, 556 U.S. 332 (2009), and Maryland v. Buie, 494 U.S. 325 (1990).
United States v. Rabinowitz, 339 U.S. 56 (1950) |
Verified |
Preston v. United States, 376 U.S. 364 (1964) |
Abstain |
New York v. Belton, 453 U.S. 454 (1981) |
Abstain |
Arizona v. Gant, 556 U.S. 332 (2009) |
Abstain |
Maryland v. Buie, 494 U.S. 325 (1990) |
Abstain |
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