## Facts

- A New York State trooper stopped a car for speeding on the New York State Thruway with four occupants, including Roger Belton.
- The trooper smelled burnt marijuana and saw an envelope on the floor that he believed contained marijuana.
- The trooper ordered the occupants out of the car and arrested them for unlawful possession of marijuana.
- After searching each arrestee, the trooper searched the car’s passenger compartment.
- The trooper found a jacket in the passenger compartment that belonged to Belton, unzipped a pocket, and discovered cocaine.
- Belton was indicted for criminal possession of a controlled substance and moved to suppress the cocaine under the Fourth and Fourteenth Amendments.
- The trial court denied suppression; Belton pleaded guilty to a lesser offense while preserving the suppression issue.
- The intermediate appellate court affirmed, but the New York Court of Appeals reversed and held the search unlawful.
- The U.S. Supreme Court granted certiorari to review the scope of a search incident to arrest in the automobile context.

## Issues

1. Whether, after a lawful custodial arrest of an automobile occupant, the Fourth Amendment permits a contemporaneous warrantless search of the vehicle’s passenger compartment as a search incident to arrest.
2. Whether the search incident to arrest doctrine allows police to open and inspect containers found in the passenger compartment, including closed containers such as a jacket pocket.

## Decision

- The Supreme Court reversed in a 6–3 decision.
- The Court held the search of Belton’s jacket pocket was a valid search incident to a lawful custodial arrest and did not violate the Fourth and Fourteenth Amendments.
- The Court adopted a categorical rule allowing officers, after arresting an occupant (or recent occupant) of a vehicle, to search the passenger compartment contemporaneously with the arrest.
- The Court further held officers may examine the contents of any containers found within the passenger compartment, whether open or closed.
- Because Belton’s jacket was in the passenger compartment, the cocaine discovered in its pocket was admissible.

## Legal Principles

- A lawful custodial arrest permits a contemporaneous warrantless search of the arrestee and the area within the arrestee’s “immediate control” to protect officer safety and prevent destruction of evidence.
- For arrests of vehicle occupants, the passenger compartment is treated as within the arrestee’s immediate control for purposes of the search-incident-to-arrest doctrine.
- When the passenger compartment is searchable incident to arrest, officers may also search containers located there, including closed containers; the authority derives from the arrest, not from diminished privacy in the container.
- The rule is intended to provide a clear, administrable standard for officers conducting vehicle arrests rather than requiring case-specific judgments about actual reach at the moment of the search.

## Conclusion

A lawful custodial arrest of an automobile occupant authorizes a contemporaneous warrantless search of the vehicle’s passenger compartment and the contents of any containers found there, including closed items such as a jacket pocket, as a search incident to arrest.


New York v. Belton, 453 U.S. 454 (1981)