User:Macwhiz/Chimel v. California (Sandbox

Chimel v. California, 395 U.S. 752 (1969), is a United States Supreme Court case in which the court held that police officers arresting a person in their home could not search the entire home without a search warrant, although they can search the area within immediate reach of the person.

Background
On September 13, 1965, three police officers came to Ted Chimel's home in Santa Ana, California with a warrant for his arrest—but not a search warrant—for the burglary of a coin shop. The officers knocked on the door, identified themselves as police officers to Chimel's wife, and asked if they might come inside. Chimel's wife admitted them to the home, where they waited 10 to 15 minutes for Chimel to return home from work. When Chimel came home, the officers handed the arrest warrant to him and asked to look around. Chimel objected, but the police told him that, "on the basis of the lawful arrest," the officers would conduct a search over his objections.

The officers had Chimel's wife accompany them through the entire three-bedroom home. The officers search included the attic, garage, and a small workshop. In some rooms, the officers directed Chimel's wife to open drawers and "to physically move the contents of the drawers from side to side, so that [they] might view any items that would have come from [the] burglary."

The officers seized numerous items, primarily coins, but also several medals, tokens, and other objects. The search took between 45 minutes and one hour.

The items the police seized were used to convict Chimel of two charges of burglary, despite Chimel's objection that they were unconstitutionally seized.

Chimel's conviction was upheld by the California Court of Appeal and the California Supreme Court. Both courts held that, although Chimel had presented sufficient evidence that the arrest warrant was invalid, the officers had obtained it "in good faith." In any event, the courts held that the arresting officers had probable cause for Chimel's arrest, making the arrest lawful—and that the subsequent search was therefore also lawful, because the search was made following a valid arrest.

Issue
Could the warrantless search of Chimel's entire house could be constitutionally justified as incident to his arrest?

Opinion of the Court
The Court held that the search of Chimel's house was unreasonable under the Fourth and Fourteenth Amendments.

The Court reasoned that searches "incident to arrest" are limited to the area within the immediate control of the suspect. While police could reasonably search and seize evidence on or around the arrestee's person, they were prohibited from rummaging through the entire house without a search warrant. The Court emphasized the importance of warrants and probable cause as necessary bulwarks against government abuse.

"When an arrest is made, it is reasonable for the arresting officer to search the person arrested in order to remove any weapons that the latter might seek to use in order to resist arrest or effect his escape. Otherwise, the officer's safety might well be endangered, and the arrest itself frustrated. In addition, it is entirely reasonable for the arresting officer to search for and seize any evidence on the arrestee's person in order to prevent its concealment or destruction. And the area into which an arrestee might reach in order to grab a weapon or evidentiary items must, of course, be governed by a like rule. A gun on a table or in a drawer in front of one who is arrested can be as dangerous to the arresting officer as one concealed in the clothing of the person arrested. There is ample justification, therefore, for a search of the arrestee's person and the area "within his immediate control"—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence.

There is no comparable justification, however, for routinely searching any room other than that in which an arrest occurs—or, for that matter, for searching through all the desk drawers or other closed or concealed areas in that room itself. Such searches, in the absence of well recognized exceptions, may be made only under the authority of a search warrant. The "adherence to judicial processes" mandated by the Fourth Amendment requires no less."

- Justice Stewart, delivering the opinion of the Court

Justice Stewart also noted that, had Chimel been arrested at his place of work, the reasoning used by the California courts would not have allowed for a search of Chimel's home without a warrant. Chimel's appeal raised the question of whether or not the police had intentionally delayed his arrest in order to arrest him in his home, so that they could make a warrantless search.

The Court overturned the conviction, stating that the officers could reasonably search only "the petitioner's person and the area from within which he might have obtained either a weapon or something that could have been used as evidence against him."

The Court's ruling in Chimel overturned Harris v. United States, 331 U.S. 145 (1947), Trupiano v. United States, 334 U.S. 699 (1948) , and United States v. Rabinowitz, 339 U.S. 56 (1950). Harris approved the search of a four-room apartment pursuant to an arrest. Trupiano involved a raid on a distillery that lead to an arrest and seizure of equipment; in that case, the Court reversed the conviction because the police had not obtained a search warrant, despite having time to do so. However, the Court overruled its Trupiano ruling in Rabinowitz. In that case, officers arrested the defendant in his one-room office under an arrest warrant, and then searched the office completely. In Rabinowitz, the Court held that it didn't matter whether or not the officers had the time and opportunity to obtain a search warrant; rather, they held that the question was whether or not the search was reasonable. The Court's ruling in Chimel resolved these often contradictory precedents.

Justice White, joined by Justice Black, dissented from the ruling. Justice White contended that precedents like Rabinowitz and Harris did not need to be overturned in order to uphold the Constitution. Instead, he suggested that there was "probable cause both for the search and for the arrest, exigent circumstances involving the removal or destruction of evidence, and satisfactory opportunity to dispute the issues of probable cause shortly thereafter." For that reason, Justices White and Black found the search to be reasonable.

Cupp v. Murphy
The Supreme Court invoked Chimel in Cupp v. Murphy, 412 U.S. 291 (1973). While at the police station house for questioning, but not under arrest, the police noticed a dark spot on Murphy's finger and proceeded to take fingernail scrapings over Murphy's protests, without a warrant.

The Court held that this search "was constitutionally permissible under the principles of Chimel v. California" because Murphy was not under arrest at the time, but was obviously aware that the detectives suspected him. Trial testimony indicated that Murphy acted suspiciously after refusing consent for the fingernail samples. Because Chimel established that a warrantless search is justified to prevent a suspect from destroying evidence readily at hand, the Court held that the police were justified in fearing that Murphy was attempting to destroy evidence under his fingernails and therefore conducting the search.

New York v. Belton
New York v. Belton, 453 U.S. 454 (1981), extended the "Chimel Rule" to automobiles. In Belton, the Court held that when a policeman makes a lawful custodial arrest of the occupant of an automobile, he may search the passenger compartment of that automobile as part of arrest.

Maryland v. Buie
In Maryland v. Buie, 494 U.S. 325 (1990), the police executed an arrest warrant against Jerome Edward Buie at his home, on charges of armed robbery. As the police searched the house for Buie, he emerged from the basement of the home and surrendered. Another officer then searched the basement, to make sure no one was hiding there. While checking the basement, the officer found a red running suit, sitting in plain view on a stack of clothing, and seized it as evidence.

The Supreme Court held that the search was permitted without a search warrant. In doing so, they identified two ways in which Buie differed from Chimel: The search in Buie was a limited search of part of the house made in an effort to find people, not a full search of the entire house for contraband; and the Buie search was made to ensure the safety of the officers against the threat of unseen people in the house, rather than being an attempt to collect evidence.

Arizona v. Gant
In Arizona v. Gant, 556 U.S. ___ (2009), the Court held that the Fourth Amendment restricts warrantless vehicular search incident to arrest conducted after the vehicle's recent occupants have been arrested and secured.