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.