People V. Riley Case Brief

Facts Riley was stopped for driving on expired license plates by San Diego police officer. The police officer found out Riley’s license was also expired, which resulted in the impounding of the his vehicle. During the inventory of the vehicle, officers found firearms stashed in a sock under his car’s hood a. People v. Riley, No. D059840, 2013 WL 475242, at *1 (Cal. Ct. App. Feb. 8, 2013). While searching Riley before his arrest, an officer found evidence of Riley’s association with the “Bloods” street gang. See Riley, 134 S. Ct. at 2480. The police seized and searched Riley’s smart phone without a warrant, which uncovered further evidence of gang relationships. The police discovered records that placed Riley’s phone at a shooting three weeks earlier. See Riley, 2013 WL 475242, at *1–2. The trial court judge denied a motion to suppress after finding that the search fell within the scope of the search-incident-to-arrest exception. See id. at *3. Riley was convicted of assault with a semiautomatic firearm, shooting at an occupied vehicle, and attempted murder.

Determination

Pp. 5–28. (a) A warrantless search is reasonable only if it falls within a specific exception to the Fourth Amendment’s warrant requirement. See Kentucky v. King, 563 U. S. ___, ___. The well-established exception at issue here applies when a warrantless search is conducted incident to a lawful arrest. Three related precedents govern the extent to which officers may search property found on or near an arrestee. Chimel v. California, 395 U. S. 752, requires that a search incident to arrest be limited to the area within the arrestee’s immediate control, where it is justified by the interests in officer safety and in preventing evidence