State v. Owens

*198CARSON, J.

Two issues under the Oregon Constitution are presented in this case: (1) whether the warrantless search of defendant’s purse, which included opening a clutch-style purse and two compact mirror cases found within the clutch-style purse and removing a transparent vial and clear plastic packet containing white powder, was justified as a search incident to arrest; and (2) whether a search warrant was required to analyze chemically the contents of lawfully seized transparent containers, when the police had probable cause to believe that they contained controlled substances.

FACTS

On May 1,…