Thornton v. United States

Thornton v. United States, 541 U.S. 615 (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 allows the officer to search the vehicle's passenger compartment as a contemporaneous incident of arrest.[1] Thornton extended New York v. Belton, 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."[2]

Thornton v. United States
Supreme Court of the United States
Argued March 31, 2004 Decided May 24, 2004
Full case name	Marcus Thornton, Petitioner v. United States
Citations	541 U.S. 615 (more) 124 S.Ct. 2127; 158 L. Ed. 2d 905; 2004 U.S. LEXIS 3681
Argument	Oral argument
Case history
Prior	325 F.3d 189 (4th Cir. 2003); cert. granted, 540 U.S. 980 (2003).
Holding
Belton governs even when an officer does not make contact until the person arrested has left the vehicle.
Court membership
Chief Justice William Rehnquist Associate Justices John P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy David Souter · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer
Case opinions
Plurality	Rehnquist, joined by Kennedy, Thomas, Breyer
Concurrence	O'Connor
Concurrence	Scalia, joined by Ginsburg
Dissent	Stevens, joined by Souter
Laws applied
U.S. Const. amend. IV

Thornton and Belton were distinguished by Arizona v. Gant,[3] 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 modifies the search incident to arrest doctrine, it also leaves intact certain legal justifications for warrantless searches set forth in Chimel v. California,[4] Thornton, and United States v. Ross.[5]

See also

• List of United States Supreme Court cases, volume 541
• List of United States Supreme Court cases

References

1. Thornton v. United States, 541 U.S. 615 (2004).  This article incorporates public domain material from this U.S government document.
2. 541 U.S. at 632.
3. Arizona v. Gant, 556 U.S. 332 (2009).
4. Chimel v. California, 395 U.S. 752 (1969).
5. United States v. Ross, 456 U.S. 798 (1982).

Further reading

• Ball, Dane C. (2005). "Thornton v. United States: Blurring Belton′s Bright Line Rule Spells Disaster for Lower Courts and the Fourth Amendment". Southwestern University Law Review. 35: 1. ISSN 0886-3296.
• Dery, G.; Hernandez, M. J. (2005). "Turning a Government Search into a Permanent Power: Thornton v. United States and the 'Progressive Distortion' of Search Incident to Arrest". William and Mary Bill of Rights Journal. 14 (2): 677–710. ISSN 1065-8254.
• Jones, C. J. (2006). "Thornton v. United States: Expanding the Scope of Search Incident to Arrest on America's Roadways". American Journal of Trial Advocacy. 30: 627. ISSN 0160-0281.
• Lewis, J. (2004). "To Serve and Protect: Thornton v. United States and the Newly Anemic Fourth Amendment". Mercer Law Review. 56: 1471. ISSN 0025-987X.

External links

• Text of Thornton v. United States, 541 U.S. 615 (2004) is available from:  Cornell  CourtListener  Findlaw  Google Scholar  Justia  Library of Congress  Oyez (oral argument audio)