Caseflicks

Supreme Court of the United States • 1969

Chimel v. California

395 U.S. 752 | 89 S. Ct. 2034 | 23 L. Ed. 2d 685 | 1969 U.S. LEXIS 1166

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Takeaway

In short, this case established the modern rule that a search incident to arrest reaches only the arrestee and the area within the arrestee's immediate control, not the entire home.

Background

Police officers arrived at Ted Chimel's home with an arrest warrant for burglary of a coin shop. After Chimel came home, the officers arrested him and asked permission to search the house. Chimel objected, but the officers searched anyway, without a search warrant. Over 45 minutes to an hour, they searched the entire three-bedroom home, including the attic, garage, workshop, drawers, and other closed areas. They seized coins and other items later introduced at trial.

Chimel was convicted of burglary. California's appellate courts agreed that the arrest warrant was defective because its supporting affidavit was conclusory, but held the arrest valid because the officers acted in good faith and had probable cause to arrest him. They further held that the complete house search was valid as incident to that arrest. The Supreme Court assumed, without deciding, that the arrest itself was constitutionally valid and reviewed whether the warrantless search of the home was permissible.

Issues

Issue #1

Whether a warrantless search incident to a lawful arrest may extend to the arrestee's entire home.

Holding

No. A search incident to arrest is limited to the arrestee's person and the area within the arrestee's immediate control—the area from which the arrestee might obtain a weapon or destroy evidence.

Reasoning

The Fourth Amendment generally requires police to obtain a search warrant before searching a home. That requirement places a neutral magistrate between law enforcement and the citizen, preventing officers from deciding for themselves when a broad invasion of domestic privacy is justified. The burden rests on the government to establish a recognized exception to the warrant requirement.

A lawful arrest creates two concrete necessities that justify a limited warrantless search. Officers may search the person arrested to remove weapons that could be used to resist or escape, and to prevent concealment or destruction of evidence. The same safety and evidence-preservation concerns justify searching the area within the arrestee's immediate reach, such as a nearby table or drawer from which the person could grab a gun or destructible evidence.

Those justifications do not support a routine exploratory search of rooms beyond the place of arrest, or a wholesale search of closed or concealed areas even in that room. Once police search beyond the area the arrestee can actually reach, the search resembles the general rummaging that the Fourth Amendment was designed to prohibit. Absent another established exception, officers must obtain a search warrant for that broader search.

The Court rejected the broad understanding of United States v. Rabinowitz and Harris v. United States, under which an arrest could authorize a search of premises under the arrestee's general possession or control. That approach lacked a principled stopping point: if an arrest in a home justified searching beyond the arrestee's reach, it could justify searching the entire house. The Court overruled those decisions insofar as they conflicted with the immediate-control rule.

Issue #2

Whether the officers' search of Chimel's entire house was reasonable under the Fourth and Fourteenth Amendments as incident to his arrest.

Holding

No. The search was unconstitutional, and the evidence seized during it could not support Chimel's conviction.

Reasoning

The officers searched far beyond Chimel's person and the area from which he could have obtained a weapon or destroyed evidence. They examined the entire house, including the attic, garage, workshop, and drawers in separate rooms, while directing Chimel's wife to move drawer contents so they could inspect them.

No search warrant authorized this extensive search, and the State identified no separate exception to the warrant requirement. The fact that Chimel was arrested inside his home did not itself make a top-to-bottom house search reasonable.

Because the seized evidence resulted from an unreasonable search, its admission at Chimel's trial violated the Fourth and Fourteenth Amendments. The Court reversed the conviction.

Concurrences

Justice Harlan

Reasoning

Justice Harlan joined the Court's opinion but wrote separately to acknowledge the federalism costs of the decision. After Mapp v. Ohio and Ker v. California applied Fourth Amendment exclusion principles to the States, changes in Fourth Amendment doctrine bind state and local officers facing varied law-enforcement conditions and differing capacities to administer warrants.

He nonetheless concluded that concern for state and local administrative burdens could not justify retaining what he regarded as unsound Fourth Amendment doctrine. In his view, the Court could not dilute the federal constitutional protection of privacy merely to give States more operational flexibility.

Dissents

Justice White

Reasoning

Justice White, joined by Justice Black, argued that the Court unnecessarily discarded the rule recognized in cases such as Harris and Rabinowitz. In his view, the Fourth Amendment prohibits unreasonable searches, not warrantless searches as such, and prior precedent generally allowed a search incident to arrest of premises under the arrestee's control when the search was reasonable.

He agreed that an arrest alone permits a search of the arrestee and the immediately accessible area for weapons and destructible evidence. But he reasoned that police may conduct a broader contemporaneous search when they have independent probable cause to search the premises and the arrest creates an exigency: the risk that accomplices or residents will remove evidence while officers leave to obtain a warrant.

On the facts of this case, Justice White believed the officers had probable cause to think stolen coins were in Chimel's house. Chimel had made statements connecting himself to the burglary, and a neighbor had reported seeing stolen property at his home. The arrest, he thought, alerted Chimel's wife and made it likely that evidence would disappear if the officers delayed their search for a warrant.

Justice White viewed the majority's rule as sacrificing evidence that police have probable cause to seize without materially increasing privacy protection. He emphasized that the suspect could promptly challenge both probable cause and the legality of the search in an adversary proceeding after arrest, and he would have upheld the search as reasonable.