The United States Supreme Court, in New York v. Belton, expanded the area in which a policeman may search after he has made a lawful custodial arrest. In so ruling, the Supreme Court dramatically departed from its previous holding in Chimel v. California. While Chimel limited the area of the search to the area "within the immediate control of the arrestee," Belton allowed a search outside of that established boundary, as the Supreme Court allowed the search to include the passenger compartment of an automobile which the arrestee had not occupied.
Glenn D. Forcucci
New York v. Belton: The Scope of Warrantless Searches Extended,
9 Pepp. L. Rev.
Available at: https://digitalcommons.pepperdine.edu/plr/vol9/iss4/6