The Florida Supreme Court had reversed appellant’s conviction for possession of methamphetamine where appellant had been arrested and taken inside a home at the time the arresting officer searched his vehicle. However, the Florida court remanded the case to determine whether the search was justified under Chimel v. California (1969) 395 U.S. 752. The question the Court granted certiorari on was whether the “bright-line” rule articulated in New York v. Belton (1981) 453 U.S. 454 is limited to situations in which the officer initiates contact with the occupant of a vehicle while that person remains inside the vehicle. The Court held that the Florida judgment was not final, and therefore certiorari was dismissed for want of jurisdiction. In certain circumstances, state court judgments can be treated as final for jurisdictional purposes even though further proceedings were to take place in the state court. None of those circumstances applied here.
Case Summaries