A search of an area immediately accessible to an arrested person is reasonable even after the arrest is concluded. The defendant argued that items seized in a search incident to her arrest should have been suppressed because at the time the search took place, the area searched was no longer accessible to her because she had already been arrested. The court, over one dissent, held that the search did not violate the Fourth Amendment because the search was reasonably contemporaneous to the arrest.
Case Summaries