In which case did the Supreme Court rule on police authority to search during an arrest?

The Supreme Court's ruling in Chimel v. California is significant because it established the scope of police authority to search a person and the immediate area surrounding them during an arrest. The case clarified that officers can conduct a search to ensure officer safety and to prevent the destruction of potential evidence. The court emphasized that the search should be limited to the arrestee's person and within their immediate control, meaning the area from which they might gain possession of a weapon or destructible evidence. This ruling set important precedents that govern what law enforcement officers can do during the arrest process, so it plays a critical role in understanding the balance between individual rights and law enforcement authority in searches associated with arrests.

In contrast, the other cases address different aspects of search and seizure law. Carroll v. United States dealt with the automobile exception to warrant requirements, Arizona v. Gant focused on searches of vehicles incident to arrest, and Riley v. California examined the need for a warrant to search digital information on a cell phone. Each of these cases adds to the body of law surrounding search and seizure, but Chimel v. California specifically addresses the immediate scope of searches when someone is arrested, making it the correct answer to the question.