Abstract
The police accused Chimel (the plaintiff) of taking part in a robbery. They arrested him in his house, but had no evidence to prosecute him for the crime. Therefore, they requested permission to search his residence. The owner refused. However, they claimed they could use the “incident to arrest” clause to do so.
Facts
Chimel was a burglary suspect. Armed with an arrest warrant, the police went to his house to arrest him. Although they wanted to search it, they waited for Chimel to come home, arrested him, and requested to “look around.” The petitioner refused. However, the police said the arrest warrant allowed them to search the house without his consent. Chimel detested this fact, but the officers ignored him and proceeded to search the house anyway. They found the stolen medals and coins. The officers presented the stolen items as evidences in court, but the defendant argued that they did so erroneously because they illegally got the items.
Issue
Should the police use an arrest warrant to justify an unwarranted search?
Decision
Lower Courts: The lower court found Chimel guilty of burglary after relying on the contentious evidence presented by the police. All appellate courts in California refused to change this judgment. However, the plaintiff received a relief from the US Supreme Court, which allowed another hearing.
Supreme Court: In a 7-to-2 judgment, Supreme Court judges ruled that the police made an error in searching the plaintiff’s house without his consent. Therefore, the pieces of evidence relied on by the lower courts were inadmissible.
Concurrence: Justice Harlan concurred with the Supreme Court’s opinion by saying that law enforcement officials needed to abide by the principles of the Fourth Amendment. He also argued that the Fourth Amendment protected American citizens from state “excesses.” Therefore, law enforcement officers needed to get a search warrant if they wanted to search a person’s house.
Dissenting Opinions: Justice White and Justice Black opposed the Supreme Court’s ruling by saying that the police would have obtained the search warrant after arresting the suspect anyway. To clarify their point, they said if the police had arrested the suspect at his workplace, they would have obtained a warrant to search his house afterwards. Furthermore, they believed that if the officers had not searched the house, Chimel’s wife would have destroyed the evidence. Therefore, they said the search was reasonable.
Discussion
The Chimel vs. California case required the Supreme Court judges to interpret Fourth Amendment rights and evaluate how they applied to the “incident to arrest” clause. The judges ruled that the police could only use such legal provisions to search the suspects and not their houses. However, the police disregarded these rights and searched all sections of his house, including the garage, attic, and workshop, without his consent, or a search warrant. The “incident to arrest” clause was only applicable to searching the suspect’s “person” (his pockets and clothes).
The court clarified this position because it understood the need for officers to search suspects for weapons when making an arrest. However, searching other places that are beyond the suspect’s control needed a search warrant. Saint Leo’s Core Value of Integrity supports the procedural application of laws in how people in authority relate to their subjects.
It does not support the “crafty” application of rules to suit a specific goal (the end does not justify the means). In the Chimel vs. California case, the police used these “crafty” methods to justify the arrest and prosecution of the plaintiff. According to Saint Leo’s Core Value of Integrity, this approach is wrong. Officers need to show integrity always.