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Chimel v. California: Case Brief

Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

The Supreme Court's Chimel v. California decision defined the scope of permissible searches following a suspect's arrest. In this lesson, you will learn about the facts of the case and the Supreme Court's landmark ruling.

Chimel v. California: The Question Presented to the Supreme Court

As the old saying goes: 'A man's home is his castle.' But what happens if the man in the old saying is arrested in his castle? What's rights does he have? Can the officer who arrests the man search the castle for weapons or other evidence of criminal activity?

In 1969, the Supreme Court of the United States was confronted with the difficult task of placing limitations on searches following arrests in the landmark Chimel v. California case.

The Fourth Amendment of the Constitution of the United States protects us from unreasonable search and seizure and is especially important in the context of police searches and arrests. This amendment has been interpreted to require warrants for both arrests and searches.

Chimel v. California presented the United States Supreme Court with a compelling Fourth Amendment question:

After the arrest of a suspect in the suspect's home, can the police search the entire house for evidence?

Facts of the Case

California police officers traveled to Chimel's home with a warrant issued for his arrest. When Chimel arrived, the officers served him with the warrant and placed him under arrest. Without first securing a search warrant or permission from Chimel, the officers began to search Chimel's home. The officer's found several items that connected Chimel to a burglary.

At trial, Chimel objected to the introduction of the items found during the search of his home and argued that the officers were not justified under the Fourth Amendment to search his home after his arrest without securing a search warrant. The prosecution argued that the officers were entitled to conduct a 'search incident to arrest' of the entire home. Chimel was ultimately convicted. He appealed his case all the way to the Supreme Court.

The Holding and Analysis of the Supreme Court

In a 7-2 decision, the Supreme Court held that the officers were not entitled to conduct a comprehensive search of Chimel's home following his arrest. In reaching this conclusion, the Court sought to better define the concept of a 'search incident to arrest'-- in other words, what kind of search a police officer can conduct after a suspect's arrest.

The Supreme Court determined that a search incident to arrest is limited to the area within the suspect's immediate control. Under this ruling, an officer is justified in searching the suspect's person for weapons or contraband but can't wander about the suspect's house looking for evidence without a search warrant. This is based on the assumption that the arrest was lawful in the first place.

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