Thursday, April 26, 2012

Chimel v. California case brief, 395 U.S. 752 (1969)

Chimel v. California
395 U.S. 752 (1969)

Procedural history
      D appealed decision from the Supreme Court of California, affirming judgments of conviction for burglary from the lower court.


Chimel (D), the arrested coin stealer, argued that the warrantless search of all rooms in his home, right after arresting him with a warrant, including the searching of desk drawers and other closed or concealed areas of the home was unreasonable, and therefore violated his Fourth Amendment rights.
-Three police officers came to Chimel's (D) house with a warrant for his arrest in connection with a robbery of a coin shop. D was arrested. Despite the fact that the officers did not have a search warrant, they asked D for permission to "look around."
-D did not consent, but the officers informed him of their intent to search his home "on the basis of the lawful arrest." D's entire house, including an attic and garage, were searched. In two rooms of the house, the officers asked D's wife to open drawers, where the evidence upon which D was convicted was found.

-Whether a warrantless search of a person’s house violates the 4th amendment when the person was lawfully arrested with a warrant.

Procedural Result
-Judgment reversed.
-A warrantless search of a person’s house violates the 4th amendment when the person was lawfully arrested with a warrant, BUT only once the search reaches beyond the area from which the arrested person could obtain a weapon or evidence.
  • A warrantless search incident to arrest is unconstitutional if it is beyond the arrested suspect's person and the area from which he could obtain a weapon or evidence.
  • The general rule allowing warrantless search of the person of an arrestee and of the area "within his control" is based upon a policy judgment.
  • The reasons behind this choice was that police officers have an interest in protecting themselves against violence and that the State has an interest in the preservation of evidence for trial.
  • However, searches beyond this limited scope are unconstitutional.
  • Otherwise, it would lead to the absurd conclusion that one's papers are safe only so long as one is not at home.
  • The privacy interest in one's home is more important than the law enforcement interest in expedient searches for evidence.
  • Thus, Rabinowitz and Harris are overturned.
-If probable cause to arrest in the home with a warrant was present, the ability to search the rest of the home without a warrant should exist, since the arrest itself supplies the exigent circumstances to do so.

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