Thornton v. United States
Thornton was convicted of possession with intent to distribute cocaine base and two firearm offenses. On appeal, he challenged the district court's refusal to suppress a firearm found in his automobile, maintaining that it was not legally obtained pursuant to a "search incident to arrest." Thornton had been approached by a police officer soon after leaving his car. After arresting Thornton, the officer searched the car and found a firearm. The district court ruled in favor of the United States. The Fourth Circuit Court of Appeals affirmed, rejecting the notion that a legal "search incident to arrest" of an automobile can only take place when the officer initiates contact with the defendant while the defendant is still in the car. The Court of Appeals noted in particular that Thornton was in close proximity to the car, and that he had exited it only moments before being confronted by the officer.
Question Presented:
Whether police officers may legally search an arrestee's automobile as part of a valid search incident to arrest if the arrestee was not in the automobile when the police stopped him.
