Category Archives: Search and Seizure

The Fourth Amendment and Drug Dog Sniffs…

In Illinois vs. Caballes, 543 U.S. 405 (2005), the United States Supreme Court ruled that law enforcement officers do not need reasonable suspicion to use a drug dog to sniff a vehicle during a legitimate traffic stop. Roy Caballes was stopped by Daniel Gillette, an Illinois State Trooper, for speeding on Interstate 80 in La [...]

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Search Incident to Arrest – Cell Phones

In United States v. Finley, 477 F.3d 250 (5th Cir. 2007), the Fifth Circuit Court of Appeals ruled that law enforcement officers may search cell phones incident to a lawful arrest. Citing both United States v. Robinson, 414 U.S. 218 (1973) and New York v. Belton, 453 U.S. 454 (1981), the Court stated “Police officers [...]

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Search Incident to Arrest – Arizona v. Gant

After many years of expanding the scope of the search incident to arrest doctrine, the United States Supreme Court took a step back in Arizona v. Gant, 556 U.S. 332 (2009). Acting on an anonymous tip that a residence in Tucson was being used to sell drugs, two Tucson police officers knocked on the front [...]

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Search Incident to Arrest – Thornton v. United States

In Thornton v. United States, 541 U.S. 615 (2004), the United States Supreme Court again expanded the authority of law enforcement officers to conduct searches incident to a lawful arrest. In Thornton the Court extended the ruling of New York v. Belton, 453 U.S. 454 (1981), to include “recent occupants” of vehicles. Marcus Thornton was [...]

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Search Incident to Arrest – New York v. Belton

In 1981, the United States Supreme Court further expanded the authority of law enforcement officers to conduct searches incident to a lawful arrest. In the case before the Court, A New York state police officer pulled over a vehicle traveling at an excessive rate of speed. The vehicle had four occupants, including Roger Belton. During [...]

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