Facts
- Santa Ana police went to Ted Steven Chimel’s home with an arrest warrant for suspected burglary of a coin shop.
- Chimel’s wife admitted the officers, who waited inside until Chimel returned.
- When Chimel arrived, officers arrested him and asked to “look around”; Chimel objected.
- Officers conducted a warrantless search of the entire three-bedroom house for 45–60 minutes, including the attic, garage, and a workshop.
- In some areas, officers directed Chimel’s wife to open drawers and move their contents so officers could inspect them.
- Police seized coins and other items later introduced at Chimel’s burglary trial over his Fourth Amendment objection.
- Chimel was convicted; California appellate courts affirmed, treating the arrest as lawful and upholding the search as incident to arrest.
- The U.S. Supreme Court granted review to determine the permissible scope of a home search incident to arrest.
Issues
- Whether a warrantless search of an arrestee’s entire home can be justified as a search incident to a lawful arrest under the Fourth and Fourteenth Amendments.
- What spatial limits the Fourth Amendment places on a search incident to arrest inside a residence.
Decision
- The Supreme Court reversed in a 6–2 decision (Justice Stewart).
- Assuming the arrest was valid, the warrantless search of Chimel’s house was not justified as incident to the arrest.
- Officers may search the arrestee’s person and the area “within the immediate control” of the arrestee.
- The search here—covering the entire home and closed or concealed areas—exceeded that permissible scope and was unreasonable under the Fourth and Fourteenth Amendments.
- Prior decisions read to permit broader searches incident to arrest were rejected to the extent inconsistent with this rule.
Legal Principles
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A search incident to arrest is justified by (1) officer safety and (2) preventing concealment or destruction of evidence.
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Incident to arrest, police may search:
- the arrestee’s person; and
- the area within the arrestee’s immediate control, meaning the area from which the arrestee might gain a weapon or destructible evidence.
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Routine searches of rooms beyond the arrest location, and searches of closed or concealed areas not within immediate control, generally require a search warrant absent another recognized exception.
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The home receives strong Fourth Amendment protection; an arrest alone does not authorize a general exploratory search of a residence.
Conclusion
The Court held that a home search incident to arrest is limited to the arrestee and the area within the arrestee’s immediate control; warrantless, house-wide searches and inspections of drawers or other closed areas are unconstitutional without a warrant or another valid exception.