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
By a 6-2 vote, the Court ruled Chimel’s trial unconstitutional and overruled Rabinowitz. Speaking for the majority, Justice Potter Stewart
The Court applied the Chimel rationale to allow more extensive searches during arrests when justified by exigent circumstances. In Maryland v. Buie
Search warrant requirement
Terry v. Ohio