Davis v. California

564 U.S. 229 (2011)

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Nature of the Case

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Facts

Officers conducted a routine traffic stop that resulted in the arrests of driver Stella Owens (for driving while intoxicated) and D (for giving a false name to police). The police handcuffed both Owens and D, and they placed the arrestees in the back of separate patrol cars. The police then searched the passenger compartment of Owens' vehicle and found a revolver inside D's jacket pocket. In his motion to suppress the revolver, D acknowledged that the officers' search fully complied with “existing Eleventh Circuit precedent.” D recognized that the District Court was obligated to follow Belton, but he raised a Fourth Amendment challenge to preserve “the issue for review” on appeal. The Supreme Court decided Gant. The Eleventh Circuit applied Gant's new rule and held that the vehicle search incident to D's arrest “violated [his] Fourth Amendment rights.” The court concluded that “penalizing the [arresting] officer” for following binding appellate precedent would do nothing to “deter . . . Fourth Amendment violations.” It affirmed D's conviction. The Supreme Court granted certiorari.