Arizona v. Gant

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Following is the case brief for Arizona v. Gant, Supreme Court of the United States, (2009)

Case Summary of Arizona v. Gant:

  • Gant was pulled over and arrested for driving while license suspended.
  • After being cuffed and secured in the back of a cop car, officers searched his car and found a gun and drugs. Gant moved to have the evidence suppressed as the result of an improper search.
  • The Arizona court convicted Gant and he petitioned to the Supreme Court claiming the search violated his Fourth Amendment rights.
  • Upon review, the United States Supreme Court held that the police may search a vehicle only if the arrested person is within reaching distance of the passenger compartment at the time of the search or reasonable belief that crime-related evidence is present in the vehicle exists.

Arizona v. Gant Case Brief

Statement of the Facts:

Gant was pulled over and arrested for driving while his license was suspended. After exiting his car, Gant was cuffed and placed in the back of the cop car. The officers then proceeded to search the passenger compartment of the vehicle, discovering a gun and cocaine.  Charged with possession of a narcotic drug and drug paraphernalia, Gant filed a motion to suppress the drug evidence relying on New York v. Belton, 435 U.S. 454 (1981), believing its ruling prevented police from searching his car after he was secured in the cop car. At trial, Gant’s motion was denied and he was later convicted.

Procedural History:

The trial court found denied the motion and convicted Gant. The Supreme Court of Arizona reversed and upheld Gant’s motion to suppress and held the search violated the Fourth Amendment. The Supreme Court of the United States granted certiorari.

Issue and Holding:

Can a police officer search an individual’s vehicle when the arrestee is not within reaching distance of the passenger compartment at the time the search is conducted? No.

Rule of Law or Legal Principle Applied:

Subsequent to a recent arrest, police may search a vehicle only if the arrested person is within the reaching distance of the passenger compartment at the time of the search or reasonable belief is established that crime-related evidence is present in the vehicle.

Judgment:

The Supreme Court of the United States affirmed the Arizona’s Supreme Court decision.

Reasoning:

  • After a recent arrest, the police may search a recent occupant’s vehicle if the arrestee is within the reaching distance of the passenger compartment during the search or it is reasonable to believe evidence related to the crime is present in the vehicle.

The Court in Chimel v. California, 395 U.S. 752 (1969) held that the basic rule that applies in these cases is that the search incident to an arrest includes the areas of the arrestee’s person and the area within his immediate control.

The Court then refers to New York v. Belton, 453 U.S. 454 (1981) where they considered the case of an arrestee in his automobile and held that police can search the arrestee’s person and conduct a contemporaneous search of the passenger compartment including any containers found therein. The Court held that this decision does not authorize a vehicle search after a recent arrest. Doing so would undermine Chimel.  

Looking at the two cases together the Court holds that officers may search a vehicle after the recent arrest of the occupant only where the unrestrained arrestee is within the reach of the passenger compartment. The search may include and objects found within the compartment.

The Court then looks to its holding in Thornton v. United States, 541 U.S. 615 (2004). In doing so it affirms that police who have stopped a vehicle, can search for evidence only when “reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle.”

Here, Gant was arrested for driving with a suspended license, cuffed and secured in the back of a squad car before any search took place. Since he was restrained he could not have had or reached a weapon. In addition, police could not have reasonably believed that it was obvious to find evidence connected to the crime for which he was arrested (driving while license suspended). A broad reading of Belton would result in a violation of the Fourth Amendment’s privacy interest.

Despite the fact that the state’s reading of Belton, has been relied on for 28 years to permit searches for minor traffic infractions, any plausible reliance interest does not trump the constitutional rights of all individuals. In addition, Stare decisis does not require a broad reading of Belton.

Concurring and Dissenting opinion:

Concurring (Scalia):

The Court must apply traditional notions of reasonableness. The preceding cases, Belton and Thornton insufficiently protect police officers because searching a vehicle is not the best way to prevent an officer from being injured. Chimel can be manipulated by officers and provides no guidance. Overruling both Belton and Thornton would be a better ruling.

Dissenting (Alito):

The Court today is actually overruling its decision in Belton. Belton has provided a test easier in application than that test decided. Belton represents a small extension of Chimel, and if the Court overrules Belton it should reexamine Chimel.

Significance:

Arizona v. Gant established that the search of an occupant’s vehicle subsequent to their arrest is permissible when:

  • Arrestee is not confined and the passenger compartment is within their immediate reach zone, or
  • Officer reasonably believes that evidence of the crime for which the occupant was arrested is in the vehicle.

Student Resources:

https://www.law.cornell.edu/supct/html/07-542.ZS.html
http://caselaw.findlaw.com/us-supreme-court/556/332.html