Can a search of a truck pursuant to a warrantless search when Naidoo was arrested be used to suppress evidence seized from the truck?

Oliva challenges the denial of his motion to suppress the evidence seized from his truck pursuant to a warrantless search when Naidoo was arrested. The government must prove an exception to the warrant requirement by a preponderance of the evidence. United States v. Vasey, 834 F.2d 782, 785 (9th Cir.1987). The district court held that the initial search was justified either as a search incident to Naidoo's arrest or as a plain view search. The district court did not address the second search of the vehicle in its order but the government argues on appeal that the second search was justified under the automobile exception.