Chimel vs. California
Chimel vs California 395 U.S. 752, 89 S. Ct. 2034, 23 L. Ed.2d 685 (1969)
A rare store coin was robbed and Ted Chimel was the main suspect according to the police investigations. On 13th September 1965, three police officers went to Chimel’s home at Santa Ana armed with an arrest warrant for the burglary of the coin store. Upon arrival at Chimel’s home the police did not find the suspect but Chimel’s wife ushered them in. Soon after, Chimel returned home and the police officers arrested him at once. Chimel protested the arrest but the officers went ahead and searched the entire house, garage and the workshop after asking ‘whether they can look around’. The police recorded the stolen coins which were later admitted into evidence despite the defendant’s protest (Carrington 562).
The trial courts in the District of Columbia found Chimel guilty of burglary. The court of appeal and the Supreme Court of Columbia upheld the previous conviction. Unsatisfied with the decisions, Chimel appealed to the Supreme Court of the United States where he cited the inadmissibility of the evidence tendered, moreover, Chimel argued that the arrest and search was unlawful and a violation of his rights under the 4th Amendment (Carrington 563).
The fact of this case was basically simple as such the issue before the court was straightforward. The main issue in this case was: whether lack of search warrant could be constitutionally justified as incidental to the arrest of the defendant and if not, whether the actions amounted to violation of the 4th amendment on people’s security against unreasonable searches and seizures (Carrington 563).
Before arriving at its decision the Supreme Court in Chimel v California case had to deal with two cases that were considered precedents in California. First, in Harris v. United States, 331 U.S. 145 (1947), the defendant was accused of violating the Mail Fraud Statute and National Stolen Property Act. He lived in an apartment with four rooms and upon securing an arrest warrant the agents searched the entire house and found draft cards which were considered property of the United States. The Court held that the evidence recovered did not violate the defendants 4th Amendment (Carrington 563).
Second, in United States v. Rabinowitz, 339 U.S 56 upon being reliably informed that the defendant with stamps bearing forged overprints. The defendant was running a one-bed room office, and upon getting an arrest warrant, the police officers arrested the defendant. The officers searched the office drawers and fount the overprints. The Court reaffirmed its decision that the search was within the ambit of arresting agencies (Carrington 563). These decisions extended the authority of arresting officers to include searches.
The majority decision was delivered by Justice Stewart in favour of Chimel. The court held that an arresting officer or agents under an arrest warrant can only search an area that is within the immediate control of the arrested person anything beyond search area is a violation under the 4th Amendment (Carrington 564). The appeal was allowed.
The Court relied partly on the case Preston v. United States, 376 U.S. 364, 367 (1964) and interpretations of the 4th Amendment. The court overruled the decisions in United States v. Rabinowitz and Harris v. United States (Carrington 565).
Do you agree/disagree with the decision
I agree with the decision as it will limit police powers in arrest where in some cases the police have been accused of planting evidence. On the other hand, the decision is unreasonable as it may allow suspects to interfere with evidence.
Carrington, Frank. Chimel v. California–A Police Response. 1970. Print. http://scholarship.law.nd.edu/cgi/viewcontent.cgi?article=3023&context=ndlr