Arizona v. Gant

Facts

On August 25, 1999, Tucson police officers Griffith and Reed acted on an anonymous tip that a house was being used to sell drugs. They knocked on the front door. Gant answered, identified himself, and said he expected the owner to return later. The officers left and ran a records check. It showed that Gant's driver's license was suspended and that there was an outstanding warrant for his arrest for driving with a suspended license. They came back that evening and arrested a man for giving a false name and a woman for possessing drug paraphernalia. Both were handcuffed and secured in separate patrol cars. Then Gant drove up, parked at the end of the driveway, got out, and shut his car door. He and Griffith met 10-to-12 feet from the car. Griffith arrested and handcuffed him. Two more officers arrived and locked Gant in the back of their vehicle. After that, two officers searched his car. One found a gun. The other found a bag of cocaine in the pocket of a jacket on the backseat. At the suppression hearing, asked why the search was conducted, Griffith answered: “Because the law says we can do it.”

Issues

1. Does the search-incident-to-arrest exception to the warrant requirement allow police to search a car after its recent occupant has been arrested, handcuffed, and locked in a patrol car, so that he cannot reach the car?
2. Did Gant's arrest for driving with a suspended license give police a reason to believe evidence of that offense might be in his car, so as to justify the search on that basis?

Holding

The search of Gant's car was unreasonable. Gant was handcuffed and secured in a patrol car and could not reach his car, and an arrest for driving with a suspended license gave no reason to expect evidence of that offense in the car. The Arizona Supreme Court was right.