Thornton v. United States
541 U.S. 615, 124 S. Ct. 2127, 158 L. Ed.2d 905 (2004)

  • A policeman ran a check on the license plate of Thornton’s car and found it had been issued to another vehicle. He followed Thornton, and when he got out of his car, the policeman asked him if he had any drugs on him. Thornton admitted that he had some drugs on him.
  • The policeman arrested Thornton and then searched Thornton’s car. Inside the car he found a gun.
  • The Trial Court convicted Thornton of possession of an illegal gun. He appealed.
    • Thornton didn’t contest the drug conviction, but argued that the policeman’s warrantless search of his vehicle was unreasonable and therefore unconstitutional under the 4th Amendment.
      • Normally, when a person is arrested, the police are allowed to search the person’s and the area within the person’s immediate control. In this case, the officer arrested Thornton outside of his vehicle, so the contents of the vehicle were not within his immediate control.
    • The police argued that it was a permissible search since it was a search incident to a lawful arrest (SILA).
      • The purposes of a SILA search are to insure that the arrestee can’t get to a weapon to attack the police with, or get to evidence that they could destroy.
        • See United States v. Robinson (414 U.S. 218 (1973)).
  • The Appellate Court upheld the conviction. Thornton appealed.
    • The Appellate Court noted that Thornton was in the immediate proximity of the car, and had exited it only moments before. Therefore the search was reasonable.
  • The US Supreme Court upheld the conviction.
    • The US Supreme Court found that so long as the arrestee is the sort of ‘recent occupant’ of a vehicle such as Thornton was, the police may search the vehicle as an incident to the arrest.
      • Under SILA you can search the area within reach of the arrestee, but that’s amorphous, so the courts have held that, in the context of a vehicle, the entire passenger compartment is searchable. It makes for a clear line.
        • Compare to Chimel v. California (395 U.S. 752 (1969)), which held that SILA was not justifiable for an entire multi-level home. It is more justifiable to search a car because they are much smaller and the size doesn’t vary much.
    • The Court found that it would be too confusing if the police had to determine exactly where the suspect was when they initiated contact.
      • The Court compared this case to New York v. Belton (453 U.S. 454 (1981), in which the police stopped a car and ordered the occupants out of the car. They then searched the car. The Court basically said in both Belton and here that it is difficult to determine exactly when a person is arrested, so there should not be a bright line rule about what the police can do based on where the person is located when the arrest was made.
    • In a concurring opinion it was argued that it as completely unreasonable to justify the search based on SILA. However, since Thornton was arrested for drug possession, there was sufficient probable cause to conduct a search of the vehicle for more drugs.