Thornton v. United States, 541 U.S. 615 (2004), was a decision by the United States Supreme Court, which held that when a police officer makes a lawful custodial arrest of an automobile's occupant, the Fourth Amendment to the United States Constitution allows the officer to search the vehicle's passenger compartment as a contemporaneous incident of arrest.
[1] Thornton extended New York v. Belton, ruling that it governs even when an officer does not make contact until the person arrested has left the vehicle.
Thornton also suggests a separate justification for an evidentiary search "when it is reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle.
Thus, while Arizona v. Gant modifies the search incident to arrest doctrine, it also leaves intact certain legal justifications for warrantless searches set forth in Chimel v. California,[4] Thornton, and United States v.
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