People v. Belton, 50 N.Y.2d 447 (1980)
A search incident to a lawful arrest must be contemporaneous with the arrest and confined to the immediate vicinity of the arrestee.
Summary
Defendant Belton was arrested just outside his apartment. Police, without a warrant, searched his apartment, ostensibly for a stolen television. The television was not found. However, they found an imitation pistol in plain view in a partially open dresser drawer in the bedroom. The New York Court of Appeals held that the search was illegal because it was not conducted pursuant to a warrant, was not incidental to the arrest (which occurred outside the apartment), and was not conducted with Belton’s consent. The court reversed the Appellate Division’s order, vacated the guilty plea and conviction, and granted the motion to suppress the physical evidence.
Facts
Defendant was arrested and handcuffed either in the hallway adjoining his apartment door or immediately inside the doorway in the foyer.
Without obtaining a warrant, police searched the defendant’s living room and bedroom, purportedly seeking a stolen television set.
The stolen television was not found during the search.
Police found an imitation pistol in plain view inside a partially open dresser drawer located in the bedroom.
Procedural History
The defendant was convicted based on evidence found during a warrantless search of his apartment.
The Appellate Division affirmed the conviction.
The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether physical evidence seized from an apartment during a warrantless search should be suppressed when the search was not conducted pursuant to a valid warrant, was not incidental to a lawful arrest, and was not conducted with the defendant’s consent.
Holding
Yes, because the search was not conducted pursuant to a valid warrant, was not incidental to the completed arrest outside the searched premises, and was not conducted with the defendant’s consent.
Court’s Reasoning
The court reasoned that the warrantless search violated the defendant’s Fourth Amendment rights. The court emphasized the well-established exceptions to the warrant requirement, which include searches conducted pursuant to a valid warrant, searches incident to a lawful arrest, and searches conducted with consent. The court found that none of these exceptions applied in this case.
The court cited Agnello v. United States, 269 U.S. 20, 33, for the proposition that warrantless searches are per se unreasonable under the Fourth Amendment, subject only to a few specifically established and well-delineated exceptions.
The court also cited Chimel v. California, 395 U.S. 752, 763, which limited the scope of a search incident to arrest to the area within the immediate control of the arrestee.
The court distinguished the present case from People v. Loria, 10 N.Y.2d 368, 373-374, without elaborating on the distinctions, but generally Loria involved consent, which was not present here.
Because the arrest occurred outside the apartment and the search was not contemporaneous with the arrest, the search could not be justified as incident to a lawful arrest. Moreover, since there was no warrant and no consent, the search was illegal, and the evidence seized should have been suppressed.