Case law · Highest court · Federal

Arizona v. Gant

Decided
April 21, 2009
Docket
07-542
Status
Published
Jurisdiction
Federal

Cited 2,725 timesNo negative treatment found in this library

What later courts said

  • holding that searching the passenger compartment of a vehicle incident to arrest is only lawful if the area is within reaching distance of the arrestee — State v. Medina (2014)
  • holding that a search of the defendant’s vehicle, when the defendant was arrested and secured inside of a patrol car, violated the Fourth Amendment — Derrick Lee Thomas v. State (2015)
  • holding that a warrantless vehicle search incident to arrest is justified “when the arrestee is unsecured and within reaching distance of the passenger compartment” — United States v. Reginald Lomax, Jr. (2018)

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

[*335] Justice Stevens delivered the opinion of the Court.

After Rodney Gant was arrested for driving with a suspended license, handcuffed, and locked in the back of a patrol car, police officers searched his car and discovered cocaine in the pocket of a jacket on the backseat. Because Gant could not have accessed his ear to retrieve weapons or evidence at the time of the search, the Arizona Supreme Court held that the search-incident-to-arrest exception to the Fourth Amendment’s warrant requirement, as defined in Chimel v. California, 395 U. S. 752 (1969), and applied to vehicle searches in New York v. Belton, 453 U. S. 454 (1981), did not justify the search in this case. We agree with that conclusion.

Under Chimel, police may search incident to arrest only the space within an arrestee’s “ ‘immediate control,’ ” meaning “the area from within which he might gain possession of a weapon or destructible evidence.” 395 U. S., at 763. The safety and evidentiary justifications underlying Chimel's reaching-distance rule determine Belton's scope. Accordingly, we hold 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. Consistent with the holding in Thornton v. United States, 541 U. S. 615 (2004), and following the suggestion in Justice Scalia’s opinion concurring in the judgment in that case, id., at 632, we also conclude that circumstances unique to the automobile context justify a search incident to arrest when it is reasonable to believe that evidence of the offense of arrest might be found in the vehicle.

Cite this

Arizona v. Gant, 556 U.S. 332 (2009)

Read the full opinion

Free account needed

Reading the library on this site uses your account’s daily calls, the same as the connector and the API. The Free plan needs no card. Calls a day on each plan.