In Maryland v. Buie, the Supreme Court ruled that the police may not, as part of a search incident to arrest, look in areas immediately adjoining the place of arrest for other persons who might attack the officers.

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In Maryland v. Buie, the Supreme Court ruled that the police may, during a lawful arrest, conduct a protective sweep of the area if they have a reasonable belief that the area to be swept harbors an individual posing a danger to those on the arrest scene. This includes looking in areas immediately adjoining the place of arrest for other persons who might attack the officers.

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