Hamel v. State

In this appeal we are asked to determine whether the search of a locked glove compartment comes within the scope of a lawful search incident to arrest, as enunciated in New York v. Belton, 1 and applied in subsequent cases. We shall hold that it does.

Following a non-jury trial in the Circuit Court for Baltimore County, Jason Keith Hamel, appellant, was convicted of a single count of possession of a firearm in connection with a drug trafficking offense. The primary evidence against appellant—the firearm and a quantity of cocaine—was admitted after denial of his motion to suppress, which was…