State Of Washington v. Rachel D. Richards

Filed Washington State Court of Appeals Division Two October 29, 2019 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION II STATE OF WASHINGTON, No. 51700-1-II Respondent, PUBLISHED OPINION v. RACHEL DARSHELL RICHARDS, Appellant. MAXA, C.J. – Rachel Richards appeals her conviction of unlawful possession of heroin.1 She argues that the trial court erred by not suppressing evidence that police officers seized in a search incident to her arrest. We hold that the officers did not exceed the scope of a lawful search incident to arrest when they searched a closed pouch in Richards’s purse…