55 N.Y.2d 49 (1982)

Under the New York State Constitution, a warrantless search of the passenger compartment of a vehicle, including closed containers visible within it, is permissible if conducted contemporaneously with a valid arrest and if the circumstances provide reason to believe that the vehicle or its contents are related to the crime for which the arrest is being made, or that a weapon may be discovered, or a means of escape thwarted.

Summary

Following a U.S. Supreme Court reversal of the New York Court of Appeals’ initial decision, this case revisits the legality of a warrantless search of a jacket found in a car’s passenger compartment after the occupants were arrested for a drug offense. The Court of Appeals, this time, upholds the search under the automobile exception to the warrant requirement of the New York State Constitution, finding probable cause to believe the vehicle contained evidence related to the crime for which the occupants were arrested.

Facts

A state trooper stopped a speeding car on the New York State Thruway. Upon approaching the vehicle, the trooper smelled marijuana and saw an envelope commonly used for marijuana sales on the car floor. The trooper ordered the four occupants, including Belton, out of the car, patted them down, and confirmed the envelope contained marijuana, leading to their arrest. Subsequently, the trooper searched the passenger compartment of the car and found Belton’s jacket on the back seat. Upon opening a zippered pocket of the jacket, he discovered cocaine.

Procedural History

The Ontario County Court denied Belton’s motion to suppress the cocaine. Belton pleaded guilty to criminal possession of a controlled substance in the sixth degree. The Appellate Division affirmed the conviction. Initially, the New York Court of Appeals reversed, holding that the search violated the Fourth Amendment. The U.S. Supreme Court reversed the Court of Appeals’ decision, finding no Fourth Amendment violation. The case was then remanded to the New York Court of Appeals to consider the issue under the New York State Constitution.

Issue(s)

Whether, under the New York State Constitution, the warrantless search of Belton’s jacket in the passenger compartment of the car was justified under an exception to the warrant requirement.

Holding

Yes, because the search fell within the automobile exception to the warrant requirement of the New York State Constitution, as the circumstances gave the trooper reason to believe that the vehicle might contain other drugs related to the crime for which the occupants were arrested.

Court’s Reasoning

The court distinguished its holding from the Supreme Court’s Fourth Amendment analysis and based its decision on the automobile exception to the warrant requirement under the New York State Constitution. The court acknowledged that the State Constitution protects individual privacy interests against unreasonable searches and seizures, but recognizes exceptions to this protection. The court found that the automobile exception is based on the reduced expectation of privacy in automobiles and their inherent mobility. It reasoned that these considerations logically apply to containers within the passenger compartment. The court emphasized that a valid arrest for a crime authorizes a warrantless search of the vehicle’s passenger compartment, including visible closed containers, when circumstances provide reason to believe that the vehicle or its contents may be related to the crime. In this case, the discovery of marijuana in the car provided such a reason. The court stated, “where police have validly arrested an occupant of an automobile, and they have reason to believe that the car may contain evidence related to the crime for which the occupant was arrested or that a weapon may be discovered or a means of escape thwarted, they may contemporaneously search the passenger compartment, including any containers found therein.” The court clarified that this holding provides meaningful guidance to police officers, delineating the area that may be searched and the circumstances that justify such a warrantless search. The court noted the search must be contemporaneous with the arrest.