Sunday, November 3, 2013

Thornton v. United States case brief

Thornton v. United States case brief summary
541 U.S. 615 (2004)

Defendant was convicted of drug and firearm offenses, but asserted that the subject firearm was discovered as the result of an unlawful search of defendant's vehicle after the detention and arrest of defendant outside the vehicle. Upon the grant of a writ of certiorari, defendant appealed the judgment of the United States Court of Appeals for the Fourth Circuit which affirmed the denial of defendant's motion to suppress the firearm.

A police officer determined that defendant's vehicle had improper license tags, but defendant parked and exited the vehicle before the officer had an opportunity to stop the vehicle. Upon contacting defendant and discovering drugs on his person, the officer arrested defendant, searched the passenger compartment of the vehicle, and discovered the firearm. Defendant contended that the officer's authority to search a vehicle upon arresting the occupant did not apply where defendant was contacted after exiting the vehicle.

  • The United States Supreme Court held, however, that the officer was allowed to search the passenger compartment of defendant's vehicle incident to the lawful custodial arrest of defendant as a recent occupant of the vehicle. 
  • The authority for the vehicle search was not limited to arrests of persons actually occupying vehicles at the time of initial contacts with officers, since the same interests in the safety of the officer and preservation of evidence applied to both occupants and recent occupants of a vehicle.

The judgment affirming the denial of defendant's motion to suppress evidence was affirmed.

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

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