State v. Craig

Hunt, C.J. —

Adam Nelson Craig appeals his conviction for unlawful possession of methamphetamine discovered on his person during a search incident to arrest for third degree driving with a suspended license. Craig contends that the search incident to arrest was unlawful because his initial driving with a suspended license arrest was “noncustodial” based on the Poulsbo Police Department’s policy of booking and releasing driving violation arrestees, which he also challenges. Holding that McKenna1 does not apply, we affirm.

FACTS

I. Administrative Booking Procedure

In September 1999, the Poulsbo…