Thornton v. United States (full text)
United States Supreme Court
Thornton v. United States, 541 U.S. 615 (2004)
Date: 05/24/04
Case No: 03-5165
Issue: Fourth Amendment Search and
Seizure, Search Incident to Arrest
Holding: The Fourth Amendment allows an officer
to search the passenger compartment of a vehicle as a
contemporaneous incident of arrest even if the person arrested left
their vehicle before the officer first made contact.
Summary:
Thornton was stopped for having license plates that did not
match the make and model of his vehicle. Before the officer had an
opportunity to pull him over, Thornton drove into a parking lot,
parked, and got out of his vehicle. During a pat down for weapons,
Thornton admitted to having marijuana and crack cocaine on his
person. The officer arrested Thornton and placed him in the patrol
car. He searched Thornton's car and found a handgun under the
driver's seat.
The Supreme Court defined the scope of a search incident to a
lawful arrest to include the area immediately surrounding the
arrestee in
Chimel v. California, 395 U.S. 752, 23 L. Ed. 2d
685, 89 S. Ct. 2034 (1969). In
New York v. Belton, 453 U.S. 454, 69 L. Ed. 2d
768, 101 S. Ct. 2860 (1981), the Court established a bright-line
rule for searches incident to arrest of automobile occupants. It
held that "when a police officer has made a lawful custodial arrest
of an occupant of an automobile, the Fourth Amendment allows the
officer to search the passenger compartment of that vehicle as a
contemporaneous incident of arrest."
On appeal, Thornton argued that
Belton was limited to situations where
the officer initiated contact with an arrestee while he was still
an occupant of the car. The Court rejected Thornton's argument and
held that the rule established in Belton applies, even if initial
contact is made after a suspect has exited his or her car. It
reasoned that "the arrest of a suspect who is next to a vehicle
presents identical concerns regarding officer safety and the
destruction of evidence as the arrest of one who is inside the
vehicle." Further, the "need for a clear rule" readily understood
by police officers justifies a general application of
Belton to include both occupants and
recent occupants of a vehicle incident to a lawful custodial
arrest.