ABSTRACT
In Harris v. United States, 331 US 145, for instance, the Court read the search- incident-to-arrest exception so broadly as to authorize a top-to-bottom search of a four-room apartment- including a sealed envelope in a closed desk drawer- following an arrest in the living room. Among the established exceptions is the rule, first suggested in Weeks v. United States, 232 US 383, that neither a warrant nor probable cause is necessary when police conduct a search, at the time of arrest, of a suspect's person and immediate surroundings. After a half century of legal uncertainty, the Court in Chimel v. California, 395 US 752, finally established a single limiting standard for incidental searches under the Fourth Amendment: Contemporaneous with a valid arrest, police may search only an arrestee's person and the area "within his immediate control." The Chimel formulation has remained the leading standard for judging the consti-tutionality of searches carried out incident to a valid arrest.
