Which case concerns a vehicle search incident to the arrest of an occupant?

• A. United States v Ross
• B. New York v Belton
• C. Chimel v California
• D. Adams v Williams

Answer: (A)

Vehicle search incident to arrest is a rule that allows police to search the interior of a vehicle at the moment of arrest of a vehicle occupant, to protect safety and preserve evidence. The leading case establishing this rule is New York v. Belton (1981). In Belton, the Supreme Court ruled that when a lawful arrest of a vehicle occupant occurs, officers may contemporaneously search the passenger compartment of the vehicle. This includes containers within that area that could conceal weapons or evidence; the trunk is generally not included unless there’s additional justification. This rule specifically addresses the scenario of an arrested occupant and the vehicle they’re in.

United States v. Ross deals with probable-cause searches of a vehicle for contraband, not a search incident to arrest. Chimel v. California covers search incident to arrest of the arrestee and the area immediately surrounding them, typically in the home, not a vehicle. Adams v. Williams concerns stop-and-frisk during a vehicle stop, not a search incident to arrest of a vehicle occupant.