[SUP]234[/SUP] Id. at 460 (quoting Chimel v. California,
395 U.S. 752,
763 (1969)). In this particular instance, Belton had been removed from the automobile and handcuffed, but the Court wished to create a general rule removed from the fact-specific nature of any one case. "'Container' here denotes any object capable of holding another object. It thus includes closed or open glove compartments, consoles, or other receptacles located anywhere within the passenger compartment, as well as luggage, boxes, bags, clothing, and the like. Our holding encompasses only the interior of the passenger compartment of an automobile and does not encompass the trunk." Id. at 460-61 n.4.
The common-law rule permitting searches of the person of an arrestee as an incident to the arrest has occasioned little controversy in the Court.[SUP]216[/SUP] The dispute has centered around the scope of the search. Since it was the stated general rule that the scope of a warrantless search must be strictly tied to and justified by the circumstances which rendered its justification permissible, and since it was the rule that the justification of a search of the arrestee was to prevent destruction of evidence and to prevent access to a weapon,[SUP]217[/SUP] it was argued to the court that a search of the person of the defendant arrested for a traffic offense, which discovered heroin in a crumpled cigarette package, was impermissible, inasmuch as there could have been no destructible evidence relating to the offense for which he was arrested and no weapon could have been concealed in the cigarette package. The Court rejected this argument, ruling that "no additional justification" is required for a custodial arrest of a suspect based on probable cause.[SUP]218[/SUP] [SUP]216[/SUP] Weeks v. United States,
232 U.S. 383,
392 (1914); Carroll v. United States,
267 U.S. 132,
158 (1925); Agnello v. United States,
269 U.S. 20,
30 (1925).
[SUP]217[/SUP] Terry v. Ohio,
392 U.S. 1,
19 (1968); Chimel v. California,
395 U.S. 752,
762, 763 (1969).
[SUP]218[/SUP] United States v. Robinson,
414 U.S. 218,
235 (1973).
See also id. at 237-38 (Justice Powell concurring). The Court applied the same rule in Gustafson v. Florida,
414 U.S. 260 (1973), involving a search of a motorist's person following his custodial arrest for an offense for which a citation would normally have issued. Unlike the situation in
Robinson, police regulations did not require the
Gustafson officer to take the suspect into custody, nor did a departmental policy guide the officer as to when to conduct a full search. The Court found these differences inconsequential, and left for another day the problem of pretextual arrests in order to obtain basis to search. Soon thereafter, the Court upheld conduct of a similar search at the place of detention, even after a time lapse between the arrest and search. United States v. Edwards,
415 U.S. 800 (1974).
