The Fourth Amendment to the United States (US) Constitution protects the citizens against unreasonable searches and seizures and warrantless arrests. Interpretations of the constitutional provision has been traditionally viewed as the conflict between the citizen’s right to privacy and the ability of the law enforcers to carry out searches and eventually, arrests. The Supreme Court has attempted to resolve the varying interpretations of the law by at least two methods: determining the reasonableness of the search on a case-to-case basis, and through the “bright-line rule” (Silk, 1987).
In New York v. Belton (1981), the bright-line rule was used as an exception for a law enforcer “who has made a lawful custodial arrest of the occupant of a car to search the passenger compartment of the car as a contemporaneous incident of the arrest.” The bright lines refer to the areas that may be searched by the police officers, and in the case of vehicle search and as established by Belton, these are the compartment and any containers inside the vehicle (Silk, 1987).
As such, police officers have been made aware that when they flag down a car, they may search the compartment and containers inside it. What they were inadequately informed about was that Belton has limitations, based on the earlier ruling on California v. Chimel (1969). According to the US Supreme Court decision on Chimel, an arresting officer may only search the area “within the immediate control” of the person arrested, or the area from which the arrestee can gain possession of a weapon or destroy evidence. This means the search is only allowed because of two conditions: it is possible that the arrestee can retrieve a gun and harm the officer, or reach the evidence and destroy it.
Police officers used Belton to justify their search incident to arrest of Rodney Joseph Gant in 2009, based on the knowledge that they are allowed to search car compartments and containers. The US Supreme Court ruled the search in Arizona v. Gant (2009) unconstitutional and reminded that the police may only search a vehicle if the arrestee is within reaching distance of the passenger compartment at the time of the search. During his arrest, Gant already stepped out of his car, was handcuffed and locked in a patrol car, with several back-up police officers on scene (Waksman, 2012). Hence, he was not within the reaching distance of his car’s compartment, and as such, he could neither harm the police officers present nor destroy evidence when he was arrested.
The decision on Gant shows that the broad reading of the Belton’s bright line rule is unfounded. Some might describe it as a vacillation of the judiciary (Silk, 1987) but through a closer reading of the jurisprudence, there are limitations that shaped judicial decisions thereafter. This paper, then shall review the changes in the interpretations of the Fourth Amendment law with the aim of informing law enforcers when they are trespassing the bounds of the Constitution.