In Thornton v. United States, the United States Supreme Court further weakened the protection afforded by the Fourth Amendment by holding that an officer may search the passenger compartment of a vehicle incident to arrest even when the suspect is first approached after exiting the vehicle. Under the guise of providing protection to police officers, this decision greatly expands the power of an arresting officer to search the private property of the arrestee and creates uncertainty on what constitutional limits apply to searches incident to arrest outside the home.
"To Serve and Protect: Thornton v. United States and the Newly Anemic Fourth Amendment,"
Mercer Law Review: Vol. 56:
4, Article 20.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol56/iss4/20