Thornton v. United States
Encyclopedia
Thornton v. United States, 541 U.S. 615
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (2004), was a decision by the United States Supreme Court, which held that when a police officer makes a lawful custodial arrest of an automobile's occupant, the Fourth Amendment to the United States Constitution
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...

 allows the officer to search the vehicle's passenger compartment as a contemporaneous incident of arrest. Thornton extended New York v. Belton
New York v. Belton
In New York v. Belton, 453 U.S. 454 , the United States Supreme Court held that when a police officer has made a lawful custodial arrest of the occupant of an automobile, the officer may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile...

, ruling that it governs even when an officer does not make contact until the person arrested has left the vehicle. Thornton also suggests a separate justification for an evidentiary search "when it is reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle." 541 U.S., at 632
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

.

Thornton and Belton were distinguished by Arizona v. Gant
Arizona v. Gant
Arizona v. Gant, 556 U.S. 332 , was a United States Supreme Court decision which held that the Fourth Amendment to the United States Constitution requires law enforcement officers to demonstrate an actual and continuing threat to their safety posed by an arrestee, or a need to preserve evidence...

, which restricted searches incident to arrest to circumstance where: 1) it is reasonable to believe that the arrested individual might access the vehicle at the time of the search; or 2) it is reasonable to believe that arrested individual's vehicle contains evidence of the offense that led to the arrest; or 3) the officer has probable cause to believe that there may be evidence of a crime concealed within the vehicle. Thus, while Arizona v. Gant
Arizona v. Gant
Arizona v. Gant, 556 U.S. 332 , was a United States Supreme Court decision which held that the Fourth Amendment to the United States Constitution requires law enforcement officers to demonstrate an actual and continuing threat to their safety posed by an arrestee, or a need to preserve evidence...

modifies the search incident to arrest doctrine, it also leaves intact certain legal justifications for warrantless searches set forth in Chimel v. California, 395 U.S. 752
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (1969), Thornton, and United States v. Ross, 456 U.S. 798
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (1982).

See also

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