Before Officer Nichols could pull over petitioner, petitioner parked and got out of his car. Nichols then parked, accosted petitioner, and arrested him after finding drugs in his pocket. Incident to the arrest, Nichols searched petitioner’s car and found a handgun under the driver’s seat. Petitioner was charged with federal drug and firearms violations. In denying his motion to suppress the firearm as the fruit of an unconstitutional search, the District Court found, inter alia, the automobile search valid under New York v. Belton, 453 U. S. 454, in which this Court held that, when a police officer makes a lawful custodial arrest of an automobile’s occupant, the Fourth Amendment allows the officer to search the vehicle’s passenger compartment as a contemporaneous incident of arrest, id., at 460. Petitioner appealed his conviction, arguing that Belton was limited to situations where the officer initiated contact with an arrestee while he was still in the car. The Fourth Circuit affirmed.

Held: Belton governs even when an officer does not make contact until the person arrested has left the vehicle. In Belton, the Court placed no reliance on the fact that the officer ordered the occupants out of the vehicle, or initiated contact with them while they remained within it. And here, there is simply no basis to conclude that the span of the area generally within the arrestee’s immediate control is determined by whether the arrestee exited the vehicle at the officer’s direction, or whether the officer initiated contact with him while he was in the car. In all relevant aspects, the arrest of a suspect who is next to a vehicle presents identical concerns regarding officer safety and evidence destruction as one who is inside. Under petitioner’s proposed “contact initiation” rule, officers who decide that it may be safer and more effective to conceal their presence until a suspect has left his car would be unable to search the passenger compartment in the event of a custodial arrest, potentially compromising their safety and placing incriminating evidence at risk of concealment or destruction. The Fourth Amendment does not require such a gamble. Belton allows police to search a car’s passenger compartment incident to a lawful arrest of both “occupants” and “recent occupants.” Ibid. While an arrestee’s status as a “recent occupant” may turn on his temporal or spatial relationship to the car at the time of the arrest and search, it certain

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Doggett v. United States, 505 U.S. 647 (1992), is a Supreme Court case addressing the right to a speedy trial under the Sixth Amendment.

Facts:

Marc Doggett was indicted in 1980 for drug-related charges. Shortly after the indictment, he left the United States. While authorities knew he was in Colombia and later Panama, they failed to apprehend him due to logistical issues. In 1982, Doggett returned to the U.S. unnoticed and lived openly for the next six years. He was arrested in 1988, but during this time, he had no knowledge of the indictment.

Issue:

Does an 8½-year delay between the indictment and arrest, largely due to government negligence, violate the defendant's Sixth Amendment right to a speedy trial?

Holding:

Yes, the Supreme Court ruled in favor of Doggett, holding that the delay violated his right to a speedy trial.

Reasoning:

The Court applied the Barker v. Wingo (1972) balancing test, which considers:

1. Length of delay: The 8½-year delay was presumptively prejudicial.
2. Reason for delay: The government was negligent in pursuing Doggett, as they could have located him with reasonable effort.
3. Defendant’s assertion of the right: Doggett could not assert his right earlier because he was unaware of the indictment.
4. Prejudice to the defendant: The Court presumed prejudice due to the excessive delay caused by government negligence, even without specific proof of harm to Doggett's defense.

Outcome:

The Court reversed Doggett’s conviction, emphasizing that a lengthy, negligent delay by the government undermines the defendant’s Sixth Amendment right, even if the defendant cannot show concrete prejudice.

This case underscores the importance of timely prosecution and holds the government accountable for unnecessary delays in pursuing charges.

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A police officer looked in an apartment window through a gap in the closed blind and observed respondents Carter and Johns and the apartment's lessee bagging cocaine. After respondents were arrested, they moved to suppress, inter alia, cocaine and other evidence obtained from the apartment and their car, arguing that the officer's initial observation was an unreasonable search in violation of the Fourth Amendment. Respondents were convicted of state drug offenses. The Minnesota trial court held that since they were not overnight social guests, they were not entitled to Fourth Amendment protection, and that the officer's observation was not a search under the Amendment. The State Court of Appeals held that Carter did not have “standing” to object to the officer's actions because the evidence indicated that he used the apartment for a business purpose—to package drugs—and, separately, affirmed Johns' conviction without addressing the “standing” issue. In reversing, the State Supreme Court held that respondents had “standing” to claim Fourth Amendment protection because they had a legitimate expectation of privacy in the invaded place, and that the officer's observation constituted an unreasonable search.

Held: Any search that may have occurred did not violate respondents' Fourth Amendment rights. The state courts' analysis of respondents' expectation of privacy under the rubric of “standing” doctrine was expressly rejected in Rakas v. Illinois, 439 U.S. 128, 140, 99 S.Ct. 421, 58 L.Ed.2d 387. Rather, to claim Fourth Amendment protection, a defendant must demonstrate that he personally has an expectation of privacy in the place searched, and that his expectation is reasonable. Id., at 143–144, n. 12, 99 S.Ct. 421. The Fourth Amendment protects persons against unreasonable searches of “their persons [and] houses,” and thus indicates that it is a personal right that must be invoked by an individual. But the extent to which the Amendment protects people may depend upon where those people are. While an overnight guest may have a legitimate expectation of privacy in someone else's home, see Minnesota v. Olson, 495 U.S. 91, 98–99, 110 S.Ct. 1684, 109 L.Ed.2d 85, one **471 who is merely present with the consent of the householder may not, see Jones v. United States, 362 U.S. 257, 259, 80 S.Ct. 725, 4 L.Ed.2d 697. And an expectation *84 of privacy in commercial property is different from, and less than, a similar expectation in a home.

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