In which case is the search of the passenger compartment justified for the purpose of gathering evidence related to the offense (for example, after an armed robbery)?

In which case is the search of the passenger compartment justified for the purpose of gathering evidence related to the offense (for example, after an armed robbery)?

• A. Carroll v United States
• B. New York v Belton
• C. Chimel v California
• D. Arizona v Grant

Answer: (D)

The key idea is how far police can go in searching a vehicle after a person is arrested. Chimel set the general rule that a search incident to arrest is limited to areas within the arrestee’s immediate control. New York v. Belton then allowed a police officer to search the passenger compartment of a vehicle incident to the arrest of its occupant, but that rule was refined later. Arizona v. Grant clarifies the current limits: a vehicle may be searched incident to arrest only if the arrestee is unsecured and within reaching distance of the passenger compartment at the time of the search, or if there is probable cause to believe the vehicle contains evidence of the offense for which the person is being arrested. In the armed-robbery scenario, there is often probable cause to believe the vehicle contains evidence related to the crime (stolen items, weapons, etc.). That probable cause justifies searching the passenger compartment of the vehicle to gather evidence, even if the arrestee isn’t within reach. So the best rule to apply here is Grant’s allowance that a vehicle search can be justified by probable cause to find evidence of the offense in the car. Carroll v. United States established the automobile exception (searches with probable cause in vehicles); Belton allowed a passenger-compartment search during a vehicle stop incident to arrest; Chimel established the limits of search incident to arrest to the arrestee’s immediate reach. Grant integrates these by tying the justification for a passenger-compartment search to probable cause that the vehicle contains evidence of the offense.

The key idea is how far police can go in searching a vehicle after a person is arrested. Chimel set the general rule that a search incident to arrest is limited to areas within the arrestee’s immediate control. New York v. Belton then allowed a police officer to search the passenger compartment of a vehicle incident to the arrest of its occupant, but that rule was refined later. Arizona v. Grant clarifies the current limits: a vehicle may be searched incident to arrest only if the arrestee is unsecured and within reaching distance of the passenger compartment at the time of the search, or if there is probable cause to believe the vehicle contains evidence of the offense for which the person is being arrested.

In the armed-robbery scenario, there is often probable cause to believe the vehicle contains evidence related to the crime (stolen items, weapons, etc.). That probable cause justifies searching the passenger compartment of the vehicle to gather evidence, even if the arrestee isn’t within reach. So the best rule to apply here is Grant’s allowance that a vehicle search can be justified by probable cause to find evidence of the offense in the car.

Carroll v. United States established the automobile exception (searches with probable cause in vehicles); Belton allowed a passenger-compartment search during a vehicle stop incident to arrest; Chimel established the limits of search incident to arrest to the arrestee’s immediate reach. Grant integrates these by tying the justification for a passenger-compartment search to probable cause that the vehicle contains evidence of the offense.