Monday, November 4, 2013

New York v. Belton case brief

New York v. Belton case brief summary
453 U.S. 454 (1981)

The state sought review of a decision of the Court of Appeals of New York that reversed a judgment of the Appellate Division of the New York Supreme Court, which upheld the constitutionality of a warrantless search of the passenger compartment of an automobile incident to a custodial arrest of defendant, an occupant thereof.

Defendant was a passenger in an automobile that sped by a police officer at a fast rate. Upon stopping the car, the officer smelled marijuana smoke and saw an envelope on the car's floor that was marked with a name for marijuana. He therefore required the occupants to get out of the vehicle and proceeded to search them. He opened the envelope and found that it contained marijuana. He also searched defendant's jacket in the vehicle and found cocaine. In defendant's subsequent drug prosecution, the trial court denied his motion to suppress the items seized in the search of the vehicle. However, the final state appellate court reversed, holding that the search of the jacket was not incident to defendant's arrest.

  • The state was granted certiorari, and the Court reversed the decision of the state court, holding that the items seized in the warrantless search of the vehicle's passenger compartment, incident to defendant's lawful custodial arrest, were justifiably seized because of the exigencies of the situation. 
  • Thus, the search did not violate the safeguards of U.S. Constitutional Amendment IV and U.S. Constitutional Amendment XIV.


The Court reversed the judgment of the lower state court and held that items seized in the warrantless search of a passenger compartment of a vehicle, incident to a lawful custodial arrest, were lawfully seized during the exigencies of the situation and such seizure did not violate the safeguards of the Fourth and Fourteenth Amendments of the constitution.

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

No comments:

Post a Comment

Exploring Career Paths: What Can You Do with a Juris Doctor Degree?

Earning a Juris Doctor (JD) degree is a significant accomplishment, opening a wide array of career paths beyond the traditional legal practi...