Which case is described as restricting the rule established by New York v. Belton?

• A. New York v Belton
• B. United States v Santana
• C. Arizona v Grant
• D. Carroll v United States

Answer: (C)

New York v. Belton established a bright-line rule that when someone is lawfully arrested, police may search the passenger compartment of the vehicle as a incident to that arrest, without needing additional justification about proximity or security. Arizona v. Grant later limited that rule, clarifying that a vehicle search incident to arrest is permissible only in two situations: the arrestee is unsecured and within reaching distance of the vehicle’s interior at the time of the search, or the police have reason to believe the vehicle contains evidence of the offense for which the person was arrested. This narrows the previous blanket approach and ties the search to specific circumstances related to proximity or potential evidence. So, the case that describes restricting the Belton rule is Arizona v. Grant.