As part of a search incident to arrest after a traffic stop, police may search the hatchback cargo area of a vehicle. The Ninth Circuit first rejected the defendant’s claims that police had lacked reasonable suspicion to detain him or probable cause to arrest him and that the scope of the investigation had been unreasonably broadened during the detention. The court then held that the most workable and straightforward rule for searches of passenger cars incident to arrest was to permit officers to search the hatchback cargo area as well as the rest of the passenger compartment. Such a search is not unreasonable because the area is generally accessible to someone in the passenger compartment, even if the cargo area has a cover.