New York v. Belton

The decision in Belton increased the police authority to conduct warrantless searches of automobiles incident to an on-the-spot arrest. Prior to the ruling, it was unclear how extensively a police officer could search the vehicle of an arrested motorist or arrested passenger. The ruling did not specifically define everything associated with warrantless searches of vehicles incident to arrest, but it clearly gave police officers in the field more breathing room. The Supreme Court finally brought its basic analysis on the issue to a conclusion in California v. Acevedo (1991), where the Court held that police may search an automobile and all the containers within the automobile if the search is supported by probable cause to believe that contraband or evidence of a crime is contained therein.