State v. Patton

¶1 This case asks us to determine the validity of an automobile search under the “incident to arrest” exception to the general warrant requirement of article I, section 7 of the Washington State Constitution. Sheriff’s deputies attempted to effectuate an arrest warrant for Randall J. Patton while he stood in his driveway next to his parked car with his head in the window. When told he was under arrest, Patton fled from the car into his home, where law enforcement officers physically detained him. They subsequently searched his car. The trial court found the search invalid as a search incident…