Grooms v. United States

Background

Joseph R. Grooms threatened to retrieve a gun and return to a bar after an argument with a bouncer. The bar called police, who found him in his car near the bar and arrested him on outstanding warrants for a moving violation and for failing to secure a load. A search of his car produced a gun. The Court granted review, allowed Grooms to proceed without fees, vacated the judgment below, and remanded the case to the Eighth Circuit for further consideration in light of the Court’s decision in Arizona v. Gant.

Reasoning

The central question is when officers may search a vehicle after arresting an occupant. Arizona v. Gant held that an officer who arrests a vehicle occupant may search the vehicle if the officer has reason to believe the vehicle contains evidence of the crime of arrest. Justice Alito, dissenting from the Court’s order, notes that this test was drawn from Justice Scalia’s earlier opinion in Thornton and that the Court did not fully explain its basis or scope. Alito points out uncertainty here: the officers had no apparent reason to believe the car held evidence of the traffic offenses for which Grooms was arrested, though it is arguable they had probable cause to arrest him for making a terroristic threat under Missouri law.

Real world impact

Because of that uncertainty about what crime the officers could lawfully rely on, the Court sent the case back for reconsideration rather than resolving the validity of the car search. The decision means lower courts must re-examine similar vehicle searches under the Gant test, and police and defendants face open questions about when such searches are lawful.

Dissents or concurrances

Justice Alito’s dissent explains why he believes the new Gant test creates significant doubt and argues the case is premature for review given uncertainty about probable cause under the state terroristic-threat statute.