In the 1980 case New York v. Belton, the U.S Supreme Court ruled that when a police officer has made a lawful custodial arrest of an occupant of an automobile, they may also search the passenger compartment of that vehicle as a contemporaneous incident of arrest. The decision was based on concerns for officer safety and evidence preservation. This ruling expanded law enforcement's ability to conduct searches without warrants under certain circumstances by establishing what is known as "the Belton rule". However, this rule was later restricted in Arizona v. Gant (2009), where it was held that such searches are only permissible if the arrested individual is within reaching distance of the compartment at the time of search or it is reasonable to believe that vehicle contains evidence related to crime for which he/she has been arrested.

In the dissenting opinion for New York v. Belton, Justice Brennan argued that the majority's decision to allow police officers to search a vehicle and its occupants without a warrant following an arrest was overly broad and violated Fourth Amendment protections against unreasonable searches and seizures. He contended that this ruling could potentially lead to abuse of power by law enforcement officials who may use it as an excuse for conducting unwarranted searches under the guise of "incident-to-arrest" circumstances. Furthermore, he expressed concern over how such a rule might disproportionately affect minority communities who are often subjected to higher rates of traffic stops and arrests. In his view, any search conducted after an arrest should be limited in scope based on what is necessary for officer safety or evidence preservation.