Vale v. Louisiana

The Court stated that even if holding that the warrantless search of a house can be justified as incident to a lawful arrest, the search must be confined to the area within the arrestee’s reach (the area from within which he might gain possession of a weapon or destructible evidence). A search may be incident to an arrest only if it is substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest. If a search of a house is to be upheld as incident to an arrest, that arrest must take place inside the house, not somewhere outside. Belief, however well founded, that evidence sought is concealed in a dwelling furnishes no justification for a search of that place without a warrant. A warrantless search of a dwelling is constitutionally valid only in “a few specifically established and well-delineated exceptions,” none of which the government had shown here.The Court stated that even if holding that the warrantless search of a house can be justified as incident to a lawful arrest, the search must be confined to the area within the arrestee’s reach (the area from within which he might gain possession of a weapon or destructible evidence). A search may be incident to an arrest only if it is substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest. If a search of a house is to be upheld as incident to an arrest, that arrest must take place inside the house, not somewhere outside. Belief, however well founded, that evidence sought is concealed in a dwelling furnishes no justification for a search of that place without a warrant. A warrantless search of a dwelling is constitutionally valid only in “a few specifically established and well-delineated exceptions,” none of which the government had shown here.