Saturday, November 2, 2013

Arizona v. Gant case brief

Arizona v. Gant case brief summary
129 S. Ct. 1710 (2009)

A trial court denied respondent's motion to suppress evidence seized from his car. Respondent was convicted of possession of a narcotic drug for sale and possession of drug paraphernalia. The Arizona Supreme Court reversed, finding that the search of respondent's car was unreasonable under the Fourth Amendment based on the search-incident-to-arrest exception. Petitioner State of Arizona petitioned for certiorari, which was granted.

After respondent 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.

  • The Court determined that the search-incident-to-arrest exception to the Fourth Amendment's warrant requirement did not justify the search because 
  • (1) police could not reasonably have believed that respondent could have accessed his car at the time of the search since the five officers outnumbered the three arrestees, all of whom had been handcuffed and secured in separate patrol cars before the officers searched respondent's car, and 
  • (2) police could not reasonably have believed that evidence of the offense for which respondent was arrested might have been found in the car since he was arrested for driving with a suspended license, an offense for which police could not expect to find evidence in the passenger compartment of his car. 
  • Also, the doctrine of stare decisis did not require adherence to a broad reading of Belton; the safety and evidentiary interests that supported the search in Belton simply were not present in the instant case.

The Court affirmed the judgment of the state supreme court. 5-4 decision; 1 concurrence; 2 dissents.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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