State v. Clausen

— Brian Clay Clausen appeals the denial of his suppression motion. He argues that the search of his vehicle was not a valid search incident to custodial arrest *659because he was initially arrested on a misdemeanor driving charge and the county jail was not booking people on such charges due to jail overcrowding. Finding that Clausen’s arrest was a custodial arrest, we affirm.

Facts

On July 18, 2001, Kalama Police Officer Steven Parker ran the license plates on a parked vehicle and discovered that the vehicle’s owner, Brian Clay Clausen, had a suspended driver’s license. Two days later, Parker and…