State v. Watson

Tyrone Watson appeals a juvenile court order denying his motion to suppress evidence seized in a search of his car. The search followed and was incident to Watson's custodial arrest for a traffic infraction. The evidence led to a charge and conviction, after a trial on stipulated facts, of unlawful possession of a controlled substance with intent to deliver. We concern ourselves only with whether the custodial arrest was valid. If it was not, the search was also invalid. State v. Davis, 35 Wn. App. 724, 669 P.2d 900 (1983), review denied, 100 Wn.2d 1039 (1984). We reverse, holding that the…