In 1973, the United States Supreme Court expanded the authority of law enforcement officers to conduct searches incident to a lawful arrest. In the case before the Court, Willie Robinson was arrested for the crime of operating a motor vehicle with a revoked license. Incident to the arrest, the arresting officer searched Robinson for weapons and found a crumpled cigarette package in Robinson’s clothing. The officer opened the cigarette package and found heroin. The Supreme Court upheld the search and ruled that law enforcement officers may open and search through all items found on the arrestee’s person even if they are in a closed container and and even if the arresting officer has no suspicion that the contents of the container are illegal. United States v. Robinson, 414 U.S. 218 (1973).
In 1969, the United States Supreme Court held that, contemporaneous with a lawful arrest, law enforcement officers can search the arrestee for weapons that could be used against the officers and to prevent the arrestee from concealing or destroying evidence. The Court limited the scope of the search to the arrestee’s person and the area within his immediate control. Chimel v. California, 395 U.S. 752 (1969).
In Chimel, the police came to Chimel’s home with an arrest warrant for an alleged burglary. They asked Chimel for permission to search his home. When Chimel refused to consent to the search, the police proceeded nonetheless to search his entire home, including the attic and garage. They also made his wife remove contents of various dresser drawers. During the course of the search, the police found and seized coins and medals which were later used to convict Chimel of burglary.
The issue in Chimel was whether a warrantless search of the area beyond the defendant’s immediate control is constitutional where the defendant is lawfully arrested inside his home. The Supreme Court answered no, and suppressed the evidence against Chimel.