In 1969,in the case of Chimel v.California,the Supreme Court:

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In the case of Chimel v. California, the Supreme Court limited the scope of searches incident to an arrest, stating that officers may only search the immediate area around the arrestee (the "grab area") for weapons or evidence that could be quickly destroyed. This ruling clarified and restricted the scope of previous cases that had allowed broader searches incident to arrest.

In 1969,in the Case of Chimel V