Supreme Court of Connecticut
State v. Jordan
October 14, 2014
Summary
Justice Espinosa concurred in the result but criticized the majority for unnecessary dicta suggesting that police acted improperly by searching the closet after arresting the defendant. She reasoned that search-incident-to-arrest analysis must account for the fluid and dangerous circumstances confronting officers and should evaluate whether access to the area was realistically possible without hindsight. The concurrence did not resolve the underlying search issue because the majority treated any error as harmless beyond a reasonable doubt.