In April 2007, police officers in Alabama pulled over Stella Owens and Willie Davis (defendant), her passenger. Owens was arrested for driving while intoxicated and Davis was arrested for giving a false name to the police. Owens and Davis were handcuffed and placed in patrol cars. The police proceeded to search the passenger compartment of Owens’ car and found a gun in the pocket of Davis’ jacket. Davis was convicted and he subsequently appealed. At the time of Davis’ arrest, New York v. Belton, 453 U.S. 454 (1981) allowed police to search the passenger compartment of a vehicle incident to a lawful arrest. While Davis’ appeal was pending, Belton was overruled by Arizona v. Gant, 556 U.S. 332 (2009). In considering Davis’ appeal, the Court of Appeals for the Eleventh Circuit applied the Gant rule and found that the search violated Davis’ Fourth Amendment rights. The Eleventh Circuit also found that applying the exclusionary rule to this case would not serve to deter future Fourth Amendment violations, and consequently did not exclude the evidence uncovered in the search. Davis’ conviction was therefore affirmed.