Tuesday, December 1, 2020

Chimel v. California [395 U.S. 752] Case Digest

 

Chimel v. California

395 U.S. 752

 

Facts:

Police officers, armed with an arrest warrant but not a search warrant, were admitted to petitioner's home by his wife, where they awaited petitioner's arrival. When he entered, he was served with the warrant. Although he denied the officers' request to "look around," they conducted a search of the entire house "on the basis of the lawful arrest." The officers directed the petitioner's wife to open drawers were they found out the coins allegedly the subject of of the offense.

At petitioner's trial on burglary charges, items taken from his home were admitted over objection that they had been unconstitutionally seized. His conviction was affirmed by the California appellate courts, which held, despite their acceptance of petitioner's contention that the arrest warrant was invalid, that, since the arresting officers had procured the warrant "in good faith," and since, in any event, they had had sufficient information to constitute probable cause for the arrest, the arrest was lawful. The courts also held that the search was justified as incident to a valid arrest.

 

Issue:

Whether or not the warrantless search of petitioner's house be constitutionally justified as incident to that lawful arrest.

 

Held:

No.

 

Ratio:

The search here went far beyond the petitioner's person and the area from within which he might have obtained either a weapon or something that could have been used as evidence against him. There was no constitutional justification, in the absence of a search warrant, for extending the search beyond that area. The scope of the search was, therefore, "unreasonable" under the Fourth and Fourteenth Amendments

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