[5] Prior to Chimel, the court's precedents permitted an arresting officer to search the area within an arrestee's "possession" and "control" for the purpose of gathering evidence.

In addition, it is entirely reasonable for the arresting officer to search for and seize any evidence on the arrestee's person in order to prevent its concealment or destruction.

And the area into which an arrestee might reach in order to grab a weapon or evidentiary items must, of course, be governed by a similar rule.

The "adherence to judicial processes" mandated by the Fourth Amendment requires no less.The ruling overturned the trial-court conviction by stating that the officers could reasonably search only "the petitioner's person and the area from within which he might have obtained either a weapon or something that could have been used as evidence against him.

"[8] In his concurring opinion in Riley v. California (2014), citing his dissent in Arizona v. Gant (2009), justice Samuel Alito called Chimel's reasoning "questionable", saying: "I think it is a mistake to allow that reasoning to affect cases like these that concern the search of the person of arrestees.