Chimel v. California

Chimel v. California was the Court's most important decision regarding warrantless searches conducted while making a valid arrest. Prior to the Chimel decision, the Harris-Rabinowitz rule, permitting searches of a premises incident to arrest, gave police a broad opportunity for abuse. The police made warrantless searches while arresting a suspect on the grounds that they did not have time to get a search warrant. But in the case of Chimel, the crime was committed a month before the arrest. After the police obtained the arrest warrant, they waited several days before serving the warrant. The police never explained why they could not get a search warrant.

The Chimel decision was important because it said that evidence seized during unlawful searches may not be used in court, a concept known as the exclusionary rule. Since Chimel limited the area of warrantless searches, it opened up the possibility that evidence seized outside of the immediate area of the suspect would be excluded and inadmissible in court, thus aiding the defendant. When Chief Justice Warren extended the use of the exclusionary rule to the states in Mapp v. Ohio (1961), the Warren Court was accused of coddling criminals. Warren resigned from the Court on 23 June 1969, the same day the Chimel case was decided. President Richard Nixon chose as his replacement a strong critic of the exclusionary rule, Warren E. Burger.

In 1971, in Williams v. United States, the Court decided that the "Chimel rule," limiting a search area to within a person's immediate control incidental to an arrest, could not be applied retroactively and should not affect searches conducted prior to the date of the Chimel decision.

Through the 1980s, the Supreme Court permitted law enforcement officers to search anything in the suspect's immediate control, meaning anywhere from which the arrestee might obtain a weapon. This included his person, the room in which he was located, and drawers. In 1990, the Court ruled that officers may make a "protective sweep" of the premises where the arrest took place. But they may only do this if they have a "reasonable belief" that a dangerous person might be there. The police may also inventory a suspect's effects without a search warrant, including a shoulder bag. Any evidence found in this manner may be used in a criminal trial.