State v. MacDicken

¶1 Abraham MacDicken appeals his convictions of two counts of first degree robbery and one count of unlawful possession of a firearm. He challenges the trial court’s denial of his motion to suppress evidence seized in a search incident to his arrest. A search incident to arrest may include the arrestee’s person and the area “from within which he might gain possession of a weapon or destructible evidence.”1 Here, officers searched Abraham MacDicken’s bags a car’s length away from where MacDicken stood in handcuffs. Because MacDicken was still within reaching distance of the bags, which the…