State v. Delfino

Defendant appeals from a judgment of conviction for unlawful possession of methamphetamine and unlawful delivery of methamphetamine. He assigns error to the court’s denial of his motion to suppress evidence that officers found during a warrantless search of defendant’s car. We conclude that the officers conducted a lawful search incident to arrest for the crime of possession of methamphetamine, even though defendant had already been removed from the car and placed under arrest for an unrelated probation violation when officers developed probable cause to believe he possessed methamphetamine…