New York v. Belton

When an officer makes a lawful arrest, the officer may, incident to that arrest, search the arrestee and the immediate surrounding area. Such searches are valid because of the need to remove any weapons the arrestee might access to resist arrest and to prevent the destruction or concealment of evidence. However, the scope of the search may not stray beyond the area within the immediate control of the arrestee.

Articles inside the relatively narrow area of the automobile passenger compartment are generally within the area into which an arrestee might reach in order to grab a weapon or evidentiary item. Therefore, an officer has made a lawful arrest of the occupant of an automobile, the officer may, incident to that arrest, search the passenger compartment of that automobile if the arrestee has access to its contents.

It follows that an officer may examine the contents of any containers found within the passenger compartment. If the passenger compartment is within the reach of the arrestee, so are containers within it. Such a container may be searched whether it is open or closed. The justification for the search is not that the arrestee has no privacy interest in the container. It is the lawful arrest that justifies the infringement of any privacy interest the arrestee may have.

In Arizona v. Gant, the U.S. Supreme Court held that the safety and evidentiary justifications underlying Chimel’s (1969) reaching-distance rule limit the holding in Belton to circumstances when a vehicle search incident to arrest is justified by those concerns. Accordingly, the majority in Gant clarified that Belton does not authorize a vehicle search incident to a recent occupant’s arrest after the arrestee has been secured and cannot access the interior of the vehicle, unless, due to circumstances unique to the automobile context, it is reasonable to believe that evidence of the offense of arrest might be found in the vehicle.