State v. Adams

¶1 The police may search a vehicle incident to the lawful arrest of a recent occupant when that person is in close temporal and spatial proximity to the *598vehicle at the time of the arrest. The arrestee may not preclude the search simply by locking the vehicle. In this case, Coryell Adams was arrested four to five feet from his car about one minute after being pulled over by a sheriff’s deputy. Because the car remained in Adams’ immediate control at the time of the arrest, the search of the vehicle was proper. We therefore affirm the court’s decision to admit evidence discovered therein.

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