Thornton v. United States Case Brief

Why is the case important?

Petitioner appealed gun charges that were brought against him when his car was searched after he had exited it and had already been arrested.

Facts of the case

“Marcus Thornton was stopped after getting out of his vehicle by a police officer who had noticed that the license plate on Thornton’s Lincoln Town Car belonged to a Chevy two-door car. During his conversation with Thornton, the officer asked if he could search him. During the search he found two bags of drugs. The officer arrested Thornton, then searched his vehicle (which Thornton had already exited by the time the police officer spoke with him, though the officer had seen him exit it). In the vehicle the officer found a gun.Thornton was convicted of drug and firearms offenses. On appeal, he moved to have the gun dismissed as evidence because, he claimed, it had been found as the result of an unconstitutional search. He argued that the officer had contacted him after he had left the vehicle and that the search therefore did not fall within the “”search incident to arrest”” exception to the Fourth Amendment warrant requirement (the exception allows police to search the person being arrested and the area “”within his immediate control””).A Fourth Circuit Court of Appeals panel rejected his argument, holding that requiring officers to signal their intent to arrest a person before he exited his vehicle would be dangerous because it would give him a chance to get any weapons in the vehicle or to use the vehicle to get away or run over the officers.”

Question

Whether, under the search incident to arrest exception to the Fourth Amendment, it is appropriate to allow evidence obtained when an officer searches the vehicle of a person they have arrested, despite the fact that they did not make contact with the person until after they left the vehicle.

Answer

“Affirmed. In affirming the judgment of the Appellate Court, the officer found that forcing officers to determine whether a suspect had noticed them before exiting the car would be too subjective

  • additionally, if weapons or contraband were inside a vehicle, these items could still be easily accessed by someone who had just exited it.”

    Conclusion

    “The Supreme Court of the United States held that Nichols was allowed to search the passenger compartment of Thornton’s vehicle incident to the lawful custodial arrest of Thornton as a recent occupant of the vehicle. The authority for the vehicle search was not limited to arrests of persons actually occupying vehicles at the time of initial contacts with officers, since the same interests in the safety of the officer and preservation of evidence applied to both occupants and recent occupants of a vehicle. So long as an arrestee was the sort of “”recent occupant”” of a vehicle, the Court ruled, the Belton Rule permitted officers to search the vehicle incident to the arrest.”

    • Case Brief: 2004
    • Petitioner: Marcus Thornton
    • Respondent: United States
    • Decided by: Rehnquist Court

    Citation: 541 US 615 (2004)
    Granted Nov 3, 2003
    Argued: Mar 31, 2004
    Decided: May 24, 2004