In the case of Arizona v. Rodney Joseph Gant, the U.S Supreme Court ruled in 2008 that police cannot search a vehicle after arresting its occupant unless they believe evidence of the crime for which he was arrested might be found in it or if the arrestee could access his vehicle to get weapons or destroy evidence. The decision came about when Tucson police arrested Rodney Gant on an outstanding warrant for driving with a suspended license and then searched his car without obtaining a warrant, finding cocaine and drug paraphernalia. Initially, Arizona courts upheld this as lawful under New York v. Belton (1981) precedent which allowed searches incident to arrests even if there's no threat from arrestees accessing their vehicles. However, upon appeal by Gant claiming violation of Fourth Amendment rights against unreasonable searches and seizures, Justice John Paul Stevens led majority opinion overturning previous ruling stating Belton had been misinterpreted over time leading to many unlawful searches.

In the dissenting opinion for Arizona v. Rodney Joseph Gant, Justice Samuel Alito argued that the majority's decision to limit police officers' ability to search a vehicle after arresting an occupant was inconsistent with previous Supreme Court rulings and could potentially endanger law enforcement personnel. He contended that this ruling would create confusion among lower courts and law enforcement officers about when such searches are permissible. Furthermore, he expressed concern that it might prevent police from discovering evidence of crime or dangerous weapons in vehicles post-arrest. The justice believed the court should have adhered more closely to its precedent set by New York v. Belton (1981), which allowed such searches as long as they were conducted contemporaneously with the arrest.