Chimel v. California

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Following is the case brief for Chimel v. California, United States Supreme Court, (1969)

Case Summary of Chimel v. California:

  • Pursuant to a valid arrest warrant, Chimel was arrested in his home after his wife permitted officers to enter.
  • Incident to arrest and absent a search warrant, the officers searched the whole house resulting in the discovery of coins which were used against Chimel at trial, despite his objections.
  • Chimel then appealed his conviction claiming the search of his whole home violated the Fourth Amendment.
  • The Supreme Court held that the search was unreasonable under the Fourth Amendment because it exceeded the scope of a warrantless search incident to a lawful arrest of the area in the possession and control of the arrestee.

Chimel v. California Case Brief

Statement of the Facts:

Officers went to Chimel’s house to arrest him for burglarizing a coin shop. The officers had a valid arrest warrant and Chimel’s wife allowed the officers inside. Once Chimel returned home, he was arrested and the officers conducted a complete search of Chimel’s home. During the search, officers instructed Chimel’s wife to handover items from their drawers and several coins, tokens and medals were seized. Despite Chimel’s objection, the seized items were introduced at trial.

Procedural History:

On appeal, the appellate court upheld the lower court’s decision stating the search of Chimel’s whole home as valid as a search incident to a lawful arrest. Chimel appealed.

Issue and Holding:

Whether a warrantless search of the entire home is permissible when the search is incident to a lawful arrest that takes place in the home? No.

Rule of Law or Legal Principle Applied:

A warrantless search incident to a lawful arrest of the area in the possession and control of the individual under arrest is permitted under the Fourth Amendment.

Judgment:

The Supreme Court reversed the lower court’s decision and overturned Chimel’s conviction.

Reasoning:

Absent a search warrant, only the area in the possession or control of the arrestee may be searched incident to a lawful arrest. It is reasonable for the police to search an arrestee to ensure officer safety and no evidence is destroyed.

In Contrast, a search of the area outside of the arrestee’s immediate control is not reasonable because it is not justifiable to ensure safety or preservation of evidence. The Fourth Amendment requirements of establishing probable cause or producing a warrant were intended to prevent the search of private homes.

Permitting a warrantless search of a private home would encourage the police to make every arrest in a suspect’s home so they could legally undertake a search absent probable cause.  Since the coins found were not in the area under the immediate control of Chimel, the search and seizure was unconstitutional.

Concurring and Dissenting opinion:

Dissenting (White):

The search was reasonable. It was not necessary for the Court to overrule precedent and hold searches of the whole home incident to arrest are per-se unreasonable. An arrest yields exigent circumstances permitting a search without a warrant when probable cause exists to believe any delay would result in the destruction of evidence.

Here, it is likely that Chimel’s wife would have moved the coins out of the home if the police had not immediately searched the home for the missing coins.

Significance:

Chimel v. California established the scope of a search incident to a lawful arrest which takes place in the arrestee’s home. Such a warrantless search is reasonable when used to search the area within the arrestee’s immediate control to ensure officer safety and prevent the destruction of evidence.

Student Resources:

https://supreme.justia.com/cases/federal/us/395/752/case.html
https://www.law.cornell.edu/supct/cert/supreme_court_2013-2014_term_highlights/fourth_amendment_warrantless_searches_incident_to_arrest