State v. Wissing

Gardner, J.:

This interlocutory appeal by the State challenges the suppression of evidence an officer found in Jonathan R. Wiss-ing’s wallet soon after his arrest. Wissing, while handcuffed, had removed his wallet from his pocket and had placed it on a dresser before tire officer retrieved it and searched it. We find, based on a categorical approach, that the officer had the authority to search the wallet incident to Wissings arrest. Accordingly, we reverse and remand.

Factual background

The underlying facts in this case are simple and undisputed. On August 4, 2015, Patrol Sergeant Jake Graber…