Copyright

Arizona v. Gant: Case Brief & Decision

Instructor: Rachael Smith

Rachael has a background in secondary education and has practiced law for eight years.

In this lesson, we will explore the 2009 case of Arizona v. Gault. We will look at how this case clarified the issue of a vehicle search incident to arrest.

Facts

Police received an anonymous tip that drugs were being sold from a house in Tucson, Arizona. When police arrived at the home, Rodney Gant answered the door, identified himself, and informed police that the owner of the home would return shortly. When police left the home, they looked up Gant's information and found that not only did he have a suspended license, but that there was also an active warrant for his arrest.

Police returned to the home later that day and arrested the occupants for various drug charges. Both were handcuffed and placed in separate patrol cars. Gant then pulled up to the home, parked, exited the vehicle, and closed the car door behind him. An officer approached Gant and handcuffed him, placing him inside a police car.

Two officers searched Gant's car; they found a gun and Gant's jacket in the backseat of his car. Inside the pocket of the jacket, officers found a bag of cocaine. Gant was arrested for not only his warrant, but also driving without a license and possession of cocaine.

Procedural History

Gant's attorney filed a motion to suppress, a legal action requesting that because evidence was obtained illegally, it should not be able to be used against him. He argued that the officers had no reason to search his car because, once he was placed under arrest for a traffic offense, a search was unlikely to produce any evidence of that offense. Additionally, because Gant was handcuffed and placed in a police car, there was no way that Gant could access any potential weapon or evidence from a jacket in his vehicle.

The trial court held that Gant's Fourth Amendment right was not violated because the search was done incident to a lawful arrest. Gant was subsequently convicted and sentenced to prison.

Gant appealed his conviction to the Arizona Supreme Court, and the appeal held that the search was unreasonable. The State of Arizona then petitioned for a writ of certiorari. A writ of certiorari is used when the law is not clear; here, the State of Arizona wanted SCOTUS to provide better guidelines as to what can be searched incident to an arrest.

Essentially, it answers the question: To what extent may officers search the passenger compartment of a vehicle incident to an arrest? SCOTUS determined that police may not search a vehicle incident to arrest once the occupant has been secured and can no longer access the vehicle.

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