Chimel v. California: Supreme Court Case, Arguments, Impact

Supreme Court ruling on warrantless searches during valid arrest

A man in handcuffs is led by an officer.

 Jochen Tack / Getty Images

In Chimel v. California (1969) the Supreme Court ruled that an arrest warrant did not give officers the opportunity to search of the arrestee's entire property. Under the Fourth Amendment, officers are required to obtain a search warrant to search, even if they have a warrant for arrest.

Key Takeaways: Chimel v. California (1969)

  • In Chimel v. California, the Supreme Court analyzed whether police officers could search a home using an arrest warrant.
  • The majority opinion found that the police officers violated Chimel's Fourth Amendment right when they searched his home without a warrant at the time of arrest.
  • The decision limited searches to the person subject to arrest and the area around that person.

Facts of the Case

On September 13, 1965, three officers approached Ted Chimel's house with a warrant for his arrest. Chimel’s wife answered the door and let the officers into their home where they could wait until Chimel returned. When he returned, the officers handed him the arrest warrant and asked to “look around.” Chimel protested but the officers insisted that the arrest warrant gave them the authority to do so. The officers proceeded to search every room of the house. In two rooms, they instructed Chimel’s wife to open drawers. They seized items that they believed to be related to the case.

In court, Chimel’s attorney argued that the arrest warrant was invalid and the warrantless search of Chimel’s home violated his Fourth Amendment right. The lower courts and the appeals courts found that the warrantless search was “incident to the arrest” which was based on good faith. The Supreme Court granted a writ of certiorari.

Constitutional Issue

Is an arrest warrant sufficient justification for officers to search a house? Under the Fourth Amendment, do officers need to get a separate search warrant to search the area around someone when placed under arrest?

The Arguments

Attorneys on behalf of the State of California argued that the officers correctly applied the Harris-Rabinowitz rule, a generally applied search and seizure doctrine formed from U.S. v. Rabinowitz and U.S. v. Harris. Together the majority opinions in those cases suggested that officers could conduct searches outside of the arrestee. In Rabinowitz, for example, the officers arrested a person in a one-room office and searched the entire room, including the contents of drawers. In each case, the Court upheld the officer’s ability to search the place where the arrest was made and seize anything connected to the crime.

Chimel’s attorney argued that the search violated Chimel’s Fourth Amendment protections because it was based on an arrest warrant and not a search warrant. The officers had plenty of time to get a separate search warrant. They waited several days before acting on the arrest warrant.

Majority Opinion

In a 7-2 decision, Justice Potter Stewart delivered the opinion of the Court. The search of Chimel's home was not "incident to the arrest." The Supreme Court rejected the Harris-Rabinowitz rule as a violation of the fundamental intent of the Fourth Amendment. According to the majority, officers violated Chimel's Fourth Amendment protections against illegal searches and seizures when they went room by room, searching his residence without a valid search warrant. Any search should have been more limited. For example, searching the subject of the arrest for weapons that might be used to get free from an arrest is reasonable.

Justice Stewart wrote:

"There is ample justification, therefore, for a search of the arrestee's person and the area "within his immediate control"—construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence."

However, Justice Stewart wrote, any further search infringes upon the Fourth Amendment. Officers must always take circumstances and the total atmosphere of the case into account but within the limits of the Fourth Amendment. The Fourth Amendment was ratified to protect members of the colonies from the warrantless searches they had experienced under British rule, according to the Justices. The probable cause requirement ensured oversight and aimed to curb police abuse of power. Allowing officers to search without probable cause because they have a search warrant defeats the purpose of the Fourth Amendment.

Dissenting Opinion

Justices White and Black dissented. They argued that the officers did not violate Chimel's Fourth Amendment protections when they searched his home after arresting him. The Justices were concerned that the majority opinion prevented police officers from conducting an "emergency search." If police were to arrest someone, leave, and return with a search warrant, they would risk losing the evidence or collecting evidence that had been altered. An arrest creates "exigent circumstances" which means that the arrest creates a situation where a reasonable person would believe that immediate action needs to be taken.

In addition, the Justices argued that a remedy to an unreasonable search is quickly available to the defendant. After an arrest, the defendant has access to an attorney and judge which is "satisfactory opportunity to dispute the issues of probable cause shortly thereafter."

Impact

In their dissenting opinion, Justices White and Black noted that the term "incident to arrest" had been narrowed and expanded four times over the course of 50 years. Chimel v. California became the fifth change. Overturning the Harris-Rabinowitz rule, the case limited "incident to arrest" to the area surrounding the person under arrest, to ensure that the person could not use a concealed weapon on the officers. All other searches require a search warrant.

The case upheld the exclusionary rule in Mapp v. Ohio which was both recent (1961) and controversial. Police power to search during an arrest was revised once more in the 1990's when the court ruled that officers may make a "protective sweep" of the area if they reasonably believe that a dangerous person might be hiding nearby.

Sources

  • Chimel v. California, 395 U.S. 752 (1969)
  • “Chimel v. California - Significance.” Jrank Law Library, law.jrank.org/pages/23992/Chimel-v-California-Significance.html.