Arizona v. Gant

Facts

Police got a tip related to drug sales. They knocked on the front door of the house and asked to speak to the owner. D answered the door and, after identifying himself, stated that he expected the owner to return later. The officers left but conducted a records check. D's driver’s license had been suspended, and there was an outstanding warrant for his arrest for driving with a suspended license. They returned to the house and found a man near the back of the house and a woman in a car parked in front of it. They arrested the man for providing a false name and the woman for possessing drug paraphernalia. Both arrestees were handcuffed and secured in separate patrol cars when D drove up. D got out of his car and shut the door. D was immediately arrested and handcuffed. D was locked in the backseat of a police car. Then two officers searched D's car: One of them found a gun, and the other discovered a bag of cocaine in the pocket of a jacket on the backseat. D was charged with two offenses-possession of a narcotic drug for sale and possession of drug paraphernalia. D moved to suppress the evidence on the ground that the warrantless search violated the Fourth Amendment. D argued that Belton did not authorize the search of his vehicle because he posed no threat to the officers after he was handcuffed in the patrol car and because he was arrested for a traffic offense for which no evidence could be found in his vehicle. The trial court rejected the State’s contention that the officers had probable cause to search D’s car for contraband when the search began, but it denied the motion to suppress. The court held that the search was permissible as a search incident to arrest. D was found guilty on both drug counts, and he was sentenced to a 3-year term of imprisonment. The Arizona Supreme Court concluded that the search was unreasonable within the meaning of the Fourth Amendment. The State appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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