New York v. Belton 1981
New York v. Belton 1981
Petitioner: State of New York
Respondent: Roger Belton
Petitioner's Claim: That a police officer did not violate the Fourth Amendment by searching Belton's jacket in a car without a search warrant.
Chief Lawyer for Petitioner: James R. Harvey
Chief Lawyer for Respondent: Paul J. Cambria, Jr.
Justices Dissenting: William J. Brennan, Jr., Thurgood Marshall, Byron R. White
Date of Decision: July 1, 1981
Decision: The Supreme Court approved the police officer's search.
Significance: With Belton, the Supreme Court said whenever the police arrest people in a car, they may search the passenger compartment without a warrant.
The Fourth Amendment of the U.S. Constitution protects privacy. Any searches and seizures undertaken by the government are required to be reasonable. In most cases, law enforcement officers must get a warrant to search a house or other private place for evidence of a crime. To get a warrant, officers must have probable cause, which means good reason to believe the place to be searched has evidence of a crime.
There are exceptions to the warrant requirement. When police officers see a person commit a felony or misdemeanor, they may arrest the person without a warrant. During the arrest, the police need to protect themselves from any weapons the criminal might have. Police also need to make sure the criminal does not destroy any evidence during the arrest. Because of these needs, police are allowed to search a person and his surroundings without a warrant when they arrest him. In New York v. Belton, the Supreme Court had to decide whether police could search inside a car after arresting the car's occupants.
On April 9, 1978, New York State Trooper Douglas Nicot was driving an unmarked police car on the New York Thruway. An automobile passed Nicot going well over the speed limit. Nicot chased the car and ordered it's driver to pull off the road. There were four men in the car, including Roger Belton.
Nicot asked to see the driver's license and automobile registration. He learned that none of the four men owned the car or was related to its owner. During the stop, Nicot smelled burnt marijuana and saw an envelope marked "Supergold" on the floor of the car. In Nicot's experience, Supergold meant marijuana. Because possessing marijuana was illegal, Nicot ordered the four men to get out of the car and arrested them.
After separating the men outside the car and patting them down, Nicot returned to the car to search it. Inside the envelope he found marijuana, just as he suspected he would. Nicot then searched the entire passenger compartment. On the back seat he found a black leather jacket. Nicot unzipped the pockets and found cocaine and Belton's identification card inside. Nicot finally took everyone to a nearby police station.
New York charged Belton with criminal possession of cocaine, a controlled substance. At Belton's trial, he made a motion to get rid of the cocaine evidence. Belton argued that Nicot violated the Fourth Amendment by searching his jacket without a search warrant. Belton said Nicot did not need to search the jacket to protect himself or the evidence because the four men already were out of the car.
The trial court denied Belton's motion. Belton pleaded guilty to a lesser offense and reserved his right to appeal the issue of whether Nicot violated the Fourth Amendment. On appeal, the Appellate Division said Nicot's search was lawful. The New York Court of Appeals, however, reversed. It said Nicot did not need to search Belton's jacket to protect himself or the evidence. Belton, then, should have gotten a warrant before searching the jacket. Faced with having to dismiss Belton's case, New York took the case to the U.S. Supreme Court.
P otter Stewart, who wrote the Supreme Court's opinion in New York v. Belton, was born on January 23, 1915, in Jackson, Michigan. After graduating from Yale Law School in 1941, Stewart worked in law firms in New York City and Cincinnati before entering Cincinnati politics in 1949. After Stewart supported Dwight D. Eisenhower's presidential campaign in 1952, Eisenhower appointed Stewart to the Sixth Circuit Court of Appeals in 1954. At thirty-nine, Stewart was the youngest federal judge in the country.
Eisenhower appointed Stewart to the Supreme Court in 1958. Stewart was a moderate justice, often casting the deciding vote in close cases. In 1962, he was the only dissenter in a case banning prayer in public schools. In an obscenity case in 1964, Stewart said that while he could not define obscenity, "I know it when I see it." In 1969, press reports suggested that Stewart was being considered to succeed Earl Warren as chief justice of the Supreme Court. Privately, Stewart asked President Richard M. Nixon not to name him to that post. In 1981 at age sixty-six, Stewart became the youngest justice to resign from the Supreme Court. He died on December 7, 1985, after suffering a stroke.
With a 6–3 decision, the Supreme Court reversed again and ruled in favor of New York. Writing for the Court, Justice Potter Stewart said confusing cases were making it hard for police officers to know what they could search without a warrant. The Supreme Court decided to change that with a clear, bright-line rule. It held that when police officers lawfully arrest the occupants of an automobile, they may search the entire passenger compartment and anything in it without a search warrant. With a clear rule, police would have no doubt what their powers are under the Fourth Amendment.
This new rule made Nicot's search lawful under the Fourth Amendment. Nicot was allowed to arrest Belton and his companions without a warrant because he saw them with marijuana. That arrest allowed Nicot to search the passenger compartment of the car, including Belton's jacket in the back seat. Because Nicot found the cocaine without violating the Fourth Amendment, New York was allowed to use the cocaine to charge Belton with criminal possession of a controlled substance.
Fourth Amendment Falls
Three justices dissented, which means they disagreed with the Court's decision. Justice William J. Brennan wrote a dissenting opinion. Brennan said the Fourth Amendment is an important tool for protecting privacy in the United States. Exceptions to the warrant requirement must be narrow if privacy is to survive. The Court's decision hurt privacy by allowing police officers to search cars without a warrant, probable cause, or any danger to police officers and evidence. Brennan did not think helping police officers with a bright-line rule was a good reason for disregarding the Fourth Amendment.
Suggestions for further reading
Franklin, Paula A. The Fourth Amendment. Englewood Cliffs: Silver Burdett Press, 1991.
Gareffa, Peter M., ed. Contemporary Newsmakers. Detroit: Gale Research Company, 1986.
Persico, Deborah A. Mapp v. Ohio: Evidence and Search Warrants. Enslow Publishers, Inc., 1997.
Shattuck, John H.F. Rights of Privacy. Skokie: National Textbook Co., 1977.
Wetterer, Charles M. The Fourth Amendment: Search and Seizure. Enslow Publishers, Inc., 1998.