The People of the State of New York v. Reggie Smith, True Name Craig Smith

Summary

The New York Court of Appeals affirmed the Appellate Division, holding that a warrantless search of a briefcase incident to arrest was permissible under both the Fourth Amendment and the New York Constitution because the container was within the arrestee's immediate control at the time of arrest. Justice Jasen filed a concurring opinion agreeing with the result but arguing for a single, uniform standard under both constitutions.