Chimel v. California

For sixty years the Supreme Court struggled with the issue of how extensive a warrantless search conducted at the time of an arrest could be. The rulings over the years ranged from a search only of the arrestee to a search of the suspect and the entire premises. The Chimel ruling settled the controversy over what could be searched without a search warrant, pursuant to an arrest. The "Chimel rule" limited such a search to the suspect and the area within his reach. This limit allowed the officers to guard against a suspect grabbing a weapon or destroying evidence, but continued to protect the suspect's right to privacy. The decision also served to prevent the police from rummaging through an entire house without a search warrant, during the course of an arrest.

On 13 September 1965 three police officers arrived at the Santa Ana, California home of Ted Chimel with a warrant for his arrest, based on information that he had been involved in the robbery of a coin shop. Chimel's wife let the officers in to wait for her husband to return home from work. When Chimel arrived home, one officer gave him the arrest warrant and asked for permission to look around. Although Chimel objected to the search, the officers stated that "on the basis of the lawful arrest," they would search the house, even though they had no search warrant. Chimel's wife objected to the search, but accompanied the officers as they searched the three-bedroom home, including the attic, garage, and workshop. In the master bedroom and sewing room, the officers told Mrs. Chimel to open drawers and move things so they could look for items from the coin shop. After the search, the officers seized numerous items, including coins, medals, and tokens.

At Chimel's state trial, the items found in the search were used as evidence against him. Chimel objected to this on the grounds that the items were seized unconstitutionally and thus should be excluded. His plea was rejected, and he was convicted. The California Court of Appeals and the California Supreme Court affirmed the conviction. Both courts held that although the arrest warrant was invalid, the arrest was lawful because the officers had obtained the warrant in good faith and had probable cause for the arrest. The courts agreed that the search of Chimel's house was justified because it was incident to a valid arrest, even though the officers did not have a search warrant.

The California courts relied on the case United States v. Rabinowitz for their decision. In this case, a one-room business office was searched at the time of the occupant's arrest, although the officers had only an arrest warrant, but not a search warrant. The Court held that a warrantless search "incident to a lawful arrest" may be made of the area that is in the possession or under the control of the arrested person. Because of United States v. Rabinowitz (1950), the California courts upheld the search of Chimel's entire house.

Before the Chimel decision, courts relied on the Harris-Rabinowitz rule for their decisions regarding searches incident to arrest. In Harris v. United States (1947), officers arrested Harris with an arrest warrant and then searched his entire four-room apartment, without a search warrant. This search was considered acceptable by the Supreme Court as being "incident to arrest."