Chimel v. California
Chimel v. California is a significant Supreme Court case that addressed the limits of police searches conducted during an arrest. The case centered around Ted Chimel, who was arrested at his home for burglary. During the arrest, police conducted a thorough search of his residence, which led to the discovery of stolen property despite Chimel's objections. The California courts initially upheld the search based on precedent from United States v. Rabinowitz, which had permitted similar warrantless searches.
However, the Supreme Court, in a 6-2 decision, ruled that the search was unconstitutional, emphasizing the need for proper legal boundaries regarding search and seizure. Justice Potter Stewart articulated that while police can search the arrestee and the area within their immediate reach for weapons or evidence, broader searches without a warrant are not justified. This case established important standards for search protocols during arrests, influencing future rulings, such as Maryland v. Buie, which allowed for more extensive searches under exigent circumstances. Overall, Chimel v. California underscores the balance between law enforcement needs and individual rights.
Chimel v. California
Date: June 23, 1969
Citation: 395 U.S. 752
Issue: Search and seizure
Significance: The Supreme Court held that when a valid arrest is made, the Fourth Amendment permits the police to search the arrested person and the area “within his immediate control,” but not any additional area.
Using an arrest warrant, the police arrested Ted Chimel at his home on burglary charges. Ignoring Chimel’s objections, the police then conducted a search of the entire house and discovered stolen property that provided the basis for Chimel’s conviction. Rejecting Chimel’s appeal, the California courts noted that the Supreme Court had upheld a similar warrantless search incident to an arrest in United States v. Rabinowitz (1950).
By a 6-2 vote, the Court ruled Chimel’s trial unconstitutional and overruled Rabinowitz. Speaking for the majority, Justice Potter Stewart recognized that it was reasonable for the police to search the person arrested in order to remove any concealed weapons and to prevent the concealment or destruction of evidence. Likewise, the police had a legitimate reason to search the area into which an arrestee might reach for a weapon.
The Court applied the Chimel rationale to allow more extensive searches during arrests when justified by exigent circumstances. In Maryland v. Buie (1990), for instance, the Court approved of a protective sweep of a home believed to harbor an individual posing a danger to the arrest scene.