Chimel v. California (1969) | Definition

Doc's CJ Glossary by Adam J. McKee
Course: Introduction / Procedural Law

Chimel v. California (1969) was a SCOTUS decision that limited the scope of a search incident to an arrest to the area in the arrestee’s immediate control.

Citation:  395 U.S. 752 (1969)

Chimel v. California (1969) was a landmark decision by the Supreme Court of the United States that established limitations on the scope of searches conducted incident to an arrest. Previously, police officers were permitted to search the entire area surrounding an arrestee, regardless of whether or not it was within the arrestee’s immediate control. This led to widespread abuse, as officers could use the arrest as a pretext to search for evidence of unrelated crimes.

In Chimel, the defendant was arrested at his home for burglary, and officers conducted a warrantless search of his entire home, including areas not within his immediate control. The Court held that such a search was unconstitutional and violated the Fourth Amendment’s prohibition on unreasonable searches and seizures. Instead, the Court ruled that police officers may only search the area within the arrestee’s immediate control, which they defined as the area from which the arrestee could reach for a weapon or destructible evidence.

The ruling in Chimel had significant implications for law enforcement and criminal justice. It established a clear limitation on the scope of searches incident to an arrest, ensuring that officers could not use an arrest as an excuse to conduct a broad and unfocused search of a person’s property. This decision helped to protect citizens’ Fourth Amendment rights and safeguard against unreasonable searches and seizures.

The Chimel decision also helped to shape subsequent decisions by the Supreme Court, including United States v. Robinson (1973) and New York v. Belton (1981), which further clarified the scope of searches incident to an arrest. In Robinson, the Court upheld the constitutionality of a search that turned up drugs during a search of a suspect’s person incident to an arrest for driving with a revoked license. In Belton, the Court extended the Chimel doctrine to searches of vehicles, ruling that police officers could conduct a search incident to an arrest of the vehicle’s occupants, even if they were no longer within reaching distance of the vehicle.

Overall, the Chimel decision played a significant role in shaping the way in which law enforcement officers conduct searches incident to an arrest. By establishing clear limitations on the scope of these searches, the decision helped to protect the Fourth Amendment rights of citizens and ensure that law enforcement officers acted within the bounds of the law.

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Last Modified:  04/08/2023

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