In the case of Chimel V. California (1969), police suspected that Chimel had robbed a rare coin store. They went to his house with an arrest warrant, and his wife let them in. They arrested him when he came home and asked him for consent to search, which he did not grant them. While inside, they searched the premises and found the coins. The police argued that they had the right to search the home because they were already inside and had a lawful arrest warrant for Chimel.
Chimel argued that while the arrest was lawful, the search was not. He appealed on the basis that they did not have a search warrant, only an arrest warrant. He argued that the evidence was inadmissible in court due to the fact that it was obtained unlawfully, and therefore could not be used against him in a court of law. Chimel believed that this constituted an unlawful search and seizure under the Fourth Amendment.
The prosecution, of course, insisted that the search and seizure were both lawful, due to the fact that the police had an arrest warrant. They argued that this gave the police the right to search the entire house, and that it was considered a "search incident to a lawful arrest," or SILA. The Appellate Court upheld the conviction, but Chimel appealed again. It was eventually overturned and reversed by the Supreme Court which ruled that the arresting officer only has the power to search the area "within the immediate control" of the person being arrested.
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