State v. Boursaw

— During a valid search of the passenger compartment of an automobile incident to the lawful arrest of the driver, an officer discovered narcotics paraphernalia and requested a K-9 unit, which arrived within 10 minutes. After the dog alerted on an area beneath the dashboard ashtray, the officer handling the dog removed the ashtray and found methamphetamine. This appeal presents the single question whether the dog search and the officer’s subsequent search behind the ashtray exceeded the duration or scope of a valid search of an automobile’s passenger compartment incident to arrest. We affirm…