Chimel v. California Case Brief: Supreme Court Limits Searches Incident to Arrest

Case Brief: Chimel v. California

Court: Supreme Court of the United States
Citation: 395 U.S. 752 (1969)
Decided: June 23, 1969

Facts:

Ted Chimel was suspected of burglarizing a coin shop. Police officers obtained an arrest warrant but not a search warrant and went to Chimel's home to arrest him. Once there, they arrested Chimel and, over his objection, conducted a comprehensive search of his home, including his attic, garage, and various drawers. The search uncovered evidence that was later used to convict Chimel. He argued that the warrantless search of his home violated the Fourth Amendment.

Issues:

1. Was the warrantless search of Chimel's home incident to his lawful arrest constitutional under the Fourth Amendment?

Holding:

The Supreme Court held that the warrantless search of Chimel's home incident to his arrest was unconstitutional. The scope of a search incident to an arrest is limited to the arrestee's person and the area within their immediate control.

Legal Reasoning:

• Fourth Amendment Protection: The Court emphasized the importance of the Fourth Amendment's protection against unreasonable searches and seizures. A search without a warrant is per se unreasonable, subject to a few specific exceptions.
• Search Incident to Arrest: The Court distinguished between permissible searches incident to arrest, which are limited to the area within the immediate control of the arrestee to ensure officer safety and prevent the destruction of evidence, and broader searches of an arrestee's home, which require a warrant.
• Immediate Control Rule: The Court defined the "immediate control" area as the area from which the arrestee might gain possession of a weapon or destructible evidence. Searches beyond this area are not justified as incident to an arrest and require a separate warrant.

Conclusion:

The Supreme Court reversed Chimel's conviction, ruling that the extensive search of his home without a search warrant exceeded the permissible scope of a search incident to an arrest. The decision established a clear limitation on the extent of searches incident to arrest, reinforcing the requirement for search warrants in most home searches.

List of Cases Cited

1. Weeks v. United States, 232 U.S. 383 (1914) - Established the exclusionary rule, barring illegally obtained evidence from use in federal courts.
2. Aguilar v. Texas, 378 U.S. 108 (1964) - Discussed the requirements for search warrants based on informants' tips.
3. Terry v. Ohio, 392 U.S. 1 (1968) - Allowed limited searches based on reasonable suspicion for officer safety.

Similar Cases

1. United States v. Robinson, 414 U.S. 218 (1973) - Upheld the search of a person incident to a lawful arrest, even without probable cause for the search itself.
2. Arizona v. Gant, 556 U.S. 332 (2009) - Clarified the scope of vehicle searches incident to arrest, limiting it to areas within the arrestee's immediate control and where evidence related to the arrest might be found.