New York v. Belton Case Brief

Why is the case important?

A police officer arrested four people in a speeding car. He examined passenger compartment, and found a jacket containing incriminating evidence.

Facts of the case

“A New York State police officer stopped a car speeding on the New York State Thruway. Roger Belton was a passenger in that car. When the officer spoke with the driver he smelled marijuana and saw an envelope he believed contained marijuana. The officer also found that none of the car’s occupants owned the car or were related to the owner of the car. After asking the four occupants of the car to get out, the officer searched the car and found a leather jacket belonging to Belton with cocaine zipped inside one of the pockets.At trial for criminal possession of a controlled substance, Belton argued that the officer seized the cocaine in violation of the Fourth and Fourteenth Amendments. The trial court denied his motion to suppress that evidence. The Appellate Division of the New York Supreme Court held that the search was constitutional, reasoning that after the officer validly arrested Belton, he could reasonably search the immediate area for more contraband. The Court of Appeals of New York reversed, holding that because Belton had no way of gaining access to the cocaine at the time the officer searched the car, the officer needed a warrant for the search he conducted.”

Question

Whether the constitutionally permissible scope of a search incident to his arrest include the passenger compartment of the automobile in which he was riding.

Answer

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.

Conclusion

“The Court reversed the judgment of the state court and held that items seized in the warrantless search of a passenger compartment of a vehicle, incident to a lawful custodial arrest, were lawfully seized during the exigencies of the situation and such seizure did not violate the safeguards of the Fourth and Fourteenth Amendments of the constitution . A policeman who has made a lawful custodial arrest of the occupant of an automobile may, as a contemporaneous incident of that arrest, search the passenger compartment of the automobile and may examine the contents of any containers found within the passenger compartment, the term “”container”” denoting any object capable of holding another object and including closed or opened glove compartments, consoles, or other receptacles, as well as luggage, boxes, bags, clothing, and the like, and (2) the search of the jacket was a search incident to a lawful custodial arrest and did not violate the Fourth and Fourteenth Amendments , it not being questioned that the jacket’s owner was the subject of a lawful custodial arrest on a charge of possessing marijuana, the search following immediately upon that arrest, and the jacket being located inside the passenger compartment of the car in which the owner had been a passenger just before he was arrested.”

  • Case Brief: 1981
  • Petitioner: New York
  • Respondent: Roger Belton
  • Decided by: Burger Court

Citation: 453 US 454 (1981)
Argued: Apr 27, 1981
Decided: Jul 1, 1981
Granted Jan 19, 1981