Rodney Gant was apprehended by Arizona state police on an outstanding warrant for driving with a suspended license. After the officers handcuffed Gant and placed him in their squad car, they went on to search his vehicle, discovering a handgun and a plastic bag of cocaine. At trial, Gant asked the judge to suppress the evidence found in his vehicle because the search had been conducted without a warrant in violation of the Fourth Amendment’s prohibition of unreasonable searches and seizures. The judge declined Gant’s request, stating that the search was a direct result of Gant’s lawful arrest and therefore an exception to the general Fourth Amendment warrant requirement. The court convicted Gant on two counts of cocaine possession. The Arizona Court of Appeals reversed, holding the search unconstitutional, and the Arizona Supreme Court agreed. The Supreme Court stated that exceptions to the Fourth Amendment warrant requirement must be justified by concerns for officer safety or evidence preservation. Because Gant left his vehicle voluntarily, the court explained, the search was not directly linked to the arrest and therefore violated the Fourth Amendment. In seeking certiorari, Arizona Attorney General Terry Goddard argued that the Arizona Supreme Court’s ruling conflicted with the Court’s precedent, as well as precedents set forth in various federal and state courts.
An officer is permitted to conduct a vehicle search when an arrestee is within reaching distance of the vehicle or it is reasonable to believe the vehicle contains evidence of the offense of arrest. Other established exceptions to the warrant requirement authorize a vehicle search when safety or evidentiary concerns demand. For instance, an officer is permitted to search a vehicle’s passenger compartment when he has reasonable suspicion that an individual, whether or not the arrestee, is “dangerous” and might access the vehicle to gain immediate control of weapons. If there is probable cause to believe a vehicle contains evidence of criminal activity, a search of any area of the vehicle in which the evidence might be found is authorized. Searches for evidence relevant to offenses other than the offense of arrest are authorized, and the scope of the search authorized is broader. Finally, there may be still other circumstances in which safety or evidentiary interests would justify a search. These exceptions together ensure that officers may search a vehicle when genuine safety or evidentiary concerns encountered during the arrest of a vehicle’s recent occupant justify a search.